Contact & FAQ

Privacy policy

Status: 27 September 2023

Table of contents

 

• Responsible
• Contact Data Protection Officer
• Overview of the processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• Use of cookies
• Business services
• Payment procedure
• Provision of the online offer and web hosting
• Contact and enquiry management
• Chatbots and chat functions
• Video conferencing, online meetings, webinars and screen sharing
• Application procedure
• Cloud services
• Newsletter and electronic notifications
• Surveys and polls
• Web analysis, monitoring and optimisation
• Online marketing
• Customer reviews and rating procedures
• Presence in social networks (social media)
• Plugins and embedded functions and content
• Management, organisation and support tools

Responsible

Hiltl AG
Jörg Stindt
Sihlstrasse 28
8001 Zurich
Switzerland

E-mail address:

[email protected]

Imprint:

https://hiltl.ch/disclaimer/

Contact Data Protection Officer

For questions regarding data protection, please contact our data protection advisor:

PlanSec AG
Dieter Huber
Sinserstrasse 67
6330 Cham
Switzerland

[email protected]
https://www.plansec.ch

Overview of the processing

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Inventory data.
• Payment details.
• Contact details.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and procedural data.
• Applicant data.
• Picture and/or video recordings.
• Event data (Facebook).

Special categories of data

• Health data.

Categories of persons concerned

• Customers.
• Employees.
• Interested parties.
• Communication partner.
• Users.
• Applicants.
• Business and contractual partners.
• Participants.
• Persons depicted.

Purposes of the processing

• Provision of contractual services and fulfilment of contractual obligations.
• Contact requests and communication.
• Safety measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organisational procedures.
• Conversion measurement.
• Target group formation.
• Managing and responding to enquiries.
• Application procedure.
• Content Delivery Network (CDN).
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

Applicable legal basis under the Swiss Data Protection Act: If you are in Switzerland, we process your data on the basis of the Swiss Federal Data Protection Act (the “Swiss DPA”). This also applies if our processing of your data otherwise concerns you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not stipulate (unlike the GDPR, for example) that a legal basis must be stated for the processing of personal data. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only obtain personal data for a specific purpose that is identifiable to the data subject and only process it in a way that is compatible with those purposes (Art. 6 para. 3 of the Swiss FADP).

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS/SSL encryption (https): To protect user data transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

International data transfers

Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DPA), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DPA). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognised in advance by the FDPIC or a competent data protection authority in another country.

According to Art. 16 of the Swiss FADP, exceptions may be allowed for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. Cookies that are strictly necessary generally include cookies with functions that serve the display and operability of the online offer , load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by users. The revocable consent will be clearly communicated to the users and will contain the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.

General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO).
• LegallyOk: Cookie consent banner for EU citizens; Service provider: Legally ok GmbH
  Schochenmühlestrasse 6
  6340 Baar
  Switzerland; website: https://www.legally-ok.com/. Privacy policy: https://www.legally-ok.com/datenschutz/.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period shall begin at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual accounts or the management report was drawn up, the commercial or business letter was received or sent or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Special categories of personal data: Health data.
• Affected persons: Customers; Interested parties. Business and contractual partners.
• Purposes of processing: provision of contractual services and fulfilment of contractual obligations; security measures; contact requests and communication; office and organisational procedures; managing and responding to requests; conversion measurement (measuring the effectiveness of marketing measures). Profiles with user-related information (creation of user profiles).
• Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Customer loyalty programme/ customer card: We process the data of the customers within the framework of our customer loyalty programme for the purpose of fulfilling the services provided to the participating customers within the framework of the customer loyalty programme. For this purpose, information collected from customers and, where necessary, identified as such, is stored in a profile of customers. In the profile, information on the use of the customer loyalty programme and on the use of the associated services and benefits is also processed and, only if necessary for the aforementioned purposes, passed on to third parties (e.g. executing service providers). The customer profiles are deleted after termination of participation and archived with the respective data only insofar as this may be necessary for legal retention purposes or the fulfilment of legal (up to 11 years in the case of tax information from the end of the year in which it arose) or contractual claims (up to three years from the end of the year of termination); legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Economic analyses and market research: For business reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. regarding services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take into account the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data); legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
• Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to contact you; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Courses and training: We process the data of the participants of our courses and trainings (uniformly referred to as “participants”) in order to be able to provide our course and training services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship. The data basically includes details of the courses and services used and, insofar as part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and evaluation of our services as well as those of the course and training instructors; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Events: We process the data of the participants of the events and similar activities offered or organised by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to take advantage of the services or promotions associated with participation.If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of disclosure (e.g. in the case of thematically oriented events or serves health care, safety or is done with the consent of the persons concerned).

  The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we obtain access to information of the end customers, employees or other persons, we process this in accordance with the legal and contractual requirements;
  Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

• Catering services: We process the data of our visitors and interested parties (uniformly referred to as “visitors”) in order to provide the ordered food and drinks as well as to provide and invoice other services and transfers.Within the scope of our commissioning, it may be necessary for us to process special categories of data within the meaning of Article 9 (1) of the Data Protection Regulation, in particular information about a person’s health. The processing is done to protect the health interests of visitors (e.g. in the case of information on allergies) and otherwise only with the visitors’ consent.

  If required for the fulfilment of the contract or required by law, or consented to by customers, or if it is based on our legitimate interests, we disclose or transfer the customers’ data e.g. to the service providers involved in the fulfilment of our services, authorities, billing offices, as well as in the area of IT, office or comparable services;
  Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Payment procedure

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to data subjects and use other service providers in addition to banks and credit institutions for this purpose (collectively “payment service providers”).

The data processed by the payment service providers include inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights.

• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); contact data (e.g. e-mail, telephone numbers).
• Affected persons: Customers; Interested parties. Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
• Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.americanexpress.com/de. Privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.
• Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract fulfilment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
• Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contract fulfilment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://pay.google.com/intl/de_de/about/. Privacy policy: https://policies.google.com/privacy.
• Saferpay: Payment services (technical connection of online payment methods); Service provider: Worldline Suisse SA, Hardturmstrasse 201, 8021 Zurich, Switzerland; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.six-payment-services.com/de/site/e-commerce/solutions/paymentsolution.html. Privacy policy: https://www.six-payment-services.com/de/services/legal/privacy-statement.html.
• TWINT: Payment services (payment systems, apps, card terminals and POS systems, transaction management); Service provider: TWINT AG, Stauffacherstrasse 41, CH-8004 Zurich, Switzerland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.twint.ch/. Privacy policy: https://www.twint.ch/datenschutz-app/.
• PostFinance: Payment processing for PostFinance customers; service provider: PostFinance AG
  Mingerstrasse 20
  3030 Bern; Website: https://www.postfinance.ch/. Privacy policy: https://www.postfinance.ch/de/detail/data.html.
• Lunch-Check: Meal vouchers as an alternative payment method; Service provider: Swiss Lunch-Check
  Gotthardstrasse 55
  8027 Zurich; website: https://lunch-check.ch/. Privacy policy: https://lunch-check.ch/datenschutzerklaerung.

Provision of the online offer and web hosting

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); security measures. Content Delivery Network (CDN).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
• Cloudflare: Content Delivery Network (CDN) – service with the help of which the content of an online offer, in particular large media files, such as graphics or programme scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the internet; service provider: Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.cloudflare.com; Privacy policy: https://www.cloudflare.com/privacypolicy/; Order processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc).
• Hostpoint: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hostpoint AG, Neue Jonastrasse 60, 8640 Rapperswil-Jona, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://support.hostpoint.ch/de/. Privacy policy: https://www.hostpoint.ch/hostpoint/kontakt-agb.html#datenschutz.

Contact and enquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the details of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Affected persons: Communication partner.
• Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Chatbots and chat functions

We offer online chats and chatbot functions (collectively referred to as “chat services”) as a communication option. A chat is an online conversation conducted with some degree of timeliness. A chatbot is software that answers users’ questions or notifies them of messages. When you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.

We would like to point out to users that the respective platform provider can find out that and when users communicate with our chat services as well as collect technical information about the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of the communication via chat services (i.e. e.g. information on who communicated with whom) could be used by the respective platform providers in accordance with their provisions, to which we refer for further information, for marketing purposes or to display advertising tailored to users.

If users agree with a chatbot to activate information with regular messages, they have the option to unsubscribe from the information at any time in the future. The chatbot informs users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages deletes user data from the list of message recipients.

We use the above information to operate our chat services, e.g. to address users personally, to respond to their queries, to deliver any requested content and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions or to identify unanswered queries).

Notes on legal basis: We use chat services on the basis of consent if we have previously obtained users’ permission to process their data within the scope of our chat services (this applies to cases where users are asked for consent, e.g. for a chatbot to send them messages on a regular basis). If we use chat services to answer users’ enquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimising the chat services, their operational efficiency and enhancing the positive user experience.

Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Affected persons: Communication partner.
• Purposes of processing: contact requests and communication; managing and responding to requests; direct marketing (e.g. by email or post).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• LiveChat: Chatbot and assistance software and associated services; Service provider: LiveChat Inc, One International Place, Suite 1400 Boston, Massachusetts 02110, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.livechatinc.com/de; Privacy policy: https://www.livechatinc.com/legal/privacy-policy/. Basis for third country transfers: EU-US Data Privacy Framework (DPF).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g. provision of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ terminal devices, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.

Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms and select the optimal security and data protection settings for you within the framework of the settings of the conference platforms. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by notifying fellow participants, locking doors and using the function to make the background unrecognisable, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorised third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in participant lists, in the case of processing of conference results, etc.). Furthermore, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
• Purposes of processing: provision of contractual services and fulfilment of contractual obligations; contact requests and communication. Office and organisational procedures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Microsoft Teams: conferencing and communications software; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.microsoft.com/de-de/microsoft-365; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Application procedure

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.

In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

If provided, applicants can submit their applications to us using an online form. The data will be transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third party providers in compliance with the legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

Processing of special categories of data: Where special categories of personal data (Art. 9(1) GDPR, e.g. health data, such as disability or ethnic origin) are requested from applicants in the context of the application procedure, they are processed in order to enable the controller or the data subject to exercise his or her rights under labour law and social security and social protection law and to comply with his or her obligations in this respect. The processing is carried out in order to enable the data subject to exercise his or her rights and comply with his or her obligations under labour law and social security and social protection law, in the case of the protection of the vital interests of applicants or other persons, or for preventive health or occupational health purposes, for the assessment of the employee’s fitness for work, for medical diagnosis, for health or social care or treatment, or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a vacancy is unsuccessful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified withdrawal by the applicants, at the latest after the expiry of a period of six months to enable us to answer any follow-up questions about the application and to comply with our obligations to provide evidence under the Equal Treatment of Applicants Regulations. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information provided by applicants voluntarily or with regard to a specific job or their qualifications).
• Persons concerned: Applicants.
• Purposes of the processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
• Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR); processing of special categories of personal data in relation to healthcare, occupation and social security (Art. 9 para. 2 lit. h) GDPR); consent to the processing of special categories of personal data (Art. 9 para. 2 lit. a) GDPR). Processing of special categories of personal data for the protection of vital interests (Art. 9(2)(c) GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.

If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g. in the case of media control).

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); image and/or video recordings (e.g. photographs or video recordings of a person).
• Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties. Communication partners.
• Purposes of processing: Office and organisational procedures; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).). Provision of contractual services and performance of contractual obligations.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Adobe Creative Cloud: Cloud storage, cloud infrastructure services and cloud-based application software, including for photo editing, video editing, graphic design, web development; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.adobe.com/de/creativecloud.html; Privacy policy: https://www.adobe.com/de/privacy.html; Order processing contract: Provided by the service provider. Basis for third country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
• Microsoft Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Order processing contract: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called “block list”) for this purpose alone.

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

 

Information about us, our services, promotions and offers.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
• Affected persons: Communication partner.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

• Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.This information is used
  for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the evaluations to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

  The measurement of opening rates and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent.

  Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted;
  Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

• Mailchimp: Email delivery and automation services; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Order processing agreement: https://mailchimp.com/legal/; Third country transfer basis: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (Are provided by the service provider). Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Surveys and polls

We conduct surveys and interviews in order to collect information for the respective communicated survey or interview purpose. The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed with the aid of a cookie).

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Affected persons: Communication partner. Participants.
• Purposes of processing: Feedback (e.g. collecting feedback via online form).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Typeform: Creation of forms as well as surveys and administration of participant contributions; Service provider: TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 – Barcelona, Spain; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.typeform.com/; Privacy policy: https://admin.typeform.com/to/dwk6gt/. Order processing contract: https://admin.typeform.com/to/dwk6gt/.

Web analysis, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Analytics 4: We use Google Analytics to measure and analyse the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides broad geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible and are not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement:
  https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms).

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Event data (Facebook) (“Event data” is data that can be transmitted by us to Facebook, e.g. via the Facebook pixel (via apps or in other ways) and relates to persons or their actions; the data includes e.g. information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is used to form target groups for content and advertising information. The event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data are deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-related profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiling with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the options for objection (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
  b) Canada: https://www.youradchoices.ca/choices.
  c) USA: https://www.aboutads.info/choices.
  d) Cross-territory: https://optout.aboutads.info.

Further guidance on processing operations, procedures and services:

• Meta pixel and target group formation (Custom Audiences): With the help of the Meta Pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for the Meta company to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Meta Ads”). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen on the basis of the websites visited) that we transmit to Meta (so-called “Custom Audiences”). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of the users and do not have a harassing effect. The Meta Pixel also allows us to track the effectiveness of the Meta Ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Meta Ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: Event data of users, i.e. .behavioural and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the Joint Accountability Agreement (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
• Facebook ads: Placement of ads within the Facebook platform and evaluation of the ad results; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Opt-out: We refer to the data protection and advertising settings in the user’s profile on the Facebook platform as well as Facebook’s consent procedure and Facebook’s contact options for exercising access and other data subject rights in Facebook’s privacy policy; Further information: Users’ event data, i.e. .behavioural and interest data, is processed for the purposes of targeted advertising and audience building based on the Shared Responsibility Agreement (“Addendum for Responsible Parties”, https://www.facebook.com/legal/controller_addendum). Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
• Google Ads and conversion measurement: online marketing practices for the purpose of placing content and ads within the service provider’s advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
• Instagram ads: Placement of ads within the Instagram platform and evaluation of the ad results; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Opt-out: We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as Instagram’s consent procedure and Instagram’s contact options for exercising access and other data subject rights in Instagram’s privacy policy; Further information: Users’ Event Data, i.e. .behavioural and interest data, is processed for the purposes of targeted advertising and audience building based on the Joint Accountability Agreement (“Accountability Addendum”, https://www.facebook.com/legal/controller_addendum). Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

Customer reviews and rating procedures

We participate in review and rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

• Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Customers; users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy.
• Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Shared responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
• LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basis third country transfer: Standard Contractual Clauses (https://legal.linkedin.com/dpa). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• TikTok: social network / video platform; service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.tiktok.com. Privacy policy: https://www.tiktok.com/de/privacy-policy.
• YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Possibility to object (opt-out): https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of the processing: Provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Fonts (obtained from the Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the provider of the fonts in the USA – When visiting our online offer, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e., the web page where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must match the font that is generated for the particular browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregate usage statistics that measure the popularity of font families. These aggregate usage statistics are published on Google Fonts’ Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregate report on top integrations based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated

Management, organisation and support tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purpose of organising, managing, planning and providing our services. When selecting the third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Jira: Web application for error management, problem handling and operational project management; Service provider: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.atlassian.com/software/jira; Privacy policy: https://www.atlassian.com/legal/privacy-policy; Order processing agreement: https://www.atlassian.com/legal/data-processing-addendum; Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (Are provided by the service provider). Further information: Data Transfer Impact Assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment
• Quandoo: online reservation system; service provider: Quandoo Switzerland GmbH,
  c/o ECOVIS ws&p ag,
  Mühlebachstrasse 2,
  8008 Zurich
  Switzerland; Website: https://www.quandoo.ch/. Privacy policy: https://www.quandoo.ch/data_privacy