Privacy Policy

1. Basic Information on Data Processing and Legal Bases

1.1. This privacy policy informs you about the type, scope, and purpose of the processing of personal data within our online offering and the websites, functions, and content associated with it (hereinafter collectively referred to as “online offering” or “website”). The privacy policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) on which the online offering is executed.

1.2. The terminology used, such as “personal data” or its “processing,” refers to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

2. Types of Processed Data / Categories of Data Subjects

2.1. The personal data of users processed within the scope of this online offering includes:

• Inventory data (e.g., names and addresses of customers),
• Contact data (e.g., email, telephone numbers),
• Communication data,
• Contract data (e.g., services utilized, names of clerks, payment information),
• Usage data (e.g., the visited websites of our online offering, interest in our products),
• Meta/communication data (e.g., device information, IP addresses), and
• Content data (e.g., entries in the contact form).

2.2. The term “user” covers all categories of persons affected by data processing. These include our business partners, customers, interested parties, and other visitors to our online offering. The terms used are to be understood as gender-neutral.

2.3. We process users’ personal data only in compliance with the relevant data protection regulations. This means that user data is only processed if there is legal permission, in particular if the data processing is necessary or legally required for the provision of our contractual services (e.g., processing of orders) and online services, if the user has given consent, or based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation and security of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR, particularly in reach measurement, creation of profiles for advertising and marketing purposes, as well as collection of access data and use of third-party services).

2.4. We point out that the legal basis for consent is Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures is Art. 6 para. 1 lit. b. GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c. GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f. GDPR.

2.5. The following persons are affected by the data processing:

• Contractual and business partners,
• Users of our online offering,
• Interested parties who are interested in our online offering or contact us for other reasons, and
• Customers.

3. Security Measures

In accordance with Art. 32 GDPR, we take appropriate organizational, contractual, and technical security measures according to the state of the art, taking into account the implementation costs and the nature, scope, circumstances, and purposes of the data processing, as well as the varying likelihood and severity of the risk to rights and freedoms, to ensure a level of protection appropriate to your data. We hereby ensure compliance with the provisions of data protection laws and protect this data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

3.1. The security measures include, in particular, the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the fact that the URL in the address bar of your browser begins with “https://”. This is a communication protocol with which data can be transmitted securely against eavesdropping within the framework of transport encryption.

4. Disclosure of Data to Third Parties and Third-Party Providers

4.1. Data is only passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if this is necessary, for example, on the basis of Art. 6 para. 1 lit. b GDPR for contractual purposes or on the basis of legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR in the economic and effective operation of our business.

4.2. We only use subcontractors to provide our services if we have taken appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of the processed personal data in accordance with the relevant legal regulations.

4.3. Insofar as content, tools, or other means from other providers (hereinafter collectively referred to as “third-party providers”) are used within the scope of this privacy policy, 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.

4.4. If we use a third-party provider whose stated registered office is in a third country (outside the European Union (EU) or the European Economic Area (EEA)), it is to be assumed that a data transfer to the third-party provider’s country of residence takes place. The transfer of data to third countries only takes place if an adequate level of data protection, user consent, or other legal permission is present.

5. Provision of Contractual Services

5.1. We process inventory data (e.g., names and addresses as well as contact data of users) and contract data (e.g., services utilized, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, through special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally. Within the framework of applicable law, we only pass this data on to third parties insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or if it is done with your consent (e.g., to involved telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities).

5.2. We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). Data disclosed to us by the contractual partner within the framework of a contractual relationship is deleted in accordance with the specifications of the contract, generally after fulfillment of the contractual services.

6. Contacting Us

6.1. When contacting us (via contact form or email), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b GDPR. In doing so, we only process the data that we need to handle your request.

6.2. The user’s details may be stored in our Customer Relationship Management system (“CRM system”) or a comparable inquiry organization.

7. Web Hosting

7.1. In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

7.2. On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

7.3. Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum duration of seven days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.

7.4. Web hosting services also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, but also further information on email dispatch (e.g., the providers involved), including the content of the respective emails, are processed. Even if our email communication has transport encryption, it is not encrypted on the servers from which it is sent and received. The content of email communication is therefore generally susceptible to manipulation.

8. Cookies & Reach Measurement

8.1. When you visit our website, information may be stored on your computer in the form of a cookie. Cookies are pieces of information that are transferred from our web server or third-party web servers to the users’ web browsers and stored there for later retrieval. Most browsers are set to automatically accept cookies. We would like to point out that use of our online offering without cookies is only possible to a limited extent. In particular, the use of your customer account is generally not possible, as the use of cookies is technically mandatory for this. However, you can also prevent the setting of certain cookies via your browser (e.g., third-party cookies), for example, if you want to prevent web tracking. You can find more information on this in the help function of your browser. Further information on third-party cookies that are set or processed when visiting our website can be found in the following privacy policy, provided we use them. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g., if user details are stored using pseudonymous online identifiers, also referred to as “user ID”).

• A distinction must be made between cookies set by the website operator when visiting a website (also “first-party cookies”) and cookies set by third-party providers (also “third-party cookies”). We only have technical control over the former cookies. We further differentiate between the following cookies.
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their browser.
• Permanent cookies: Permanent cookies remain stored even after the browser 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, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
• Necessary (also: essential or strictly necessary) cookies: Cookies can, on the one hand, be strictly necessary for the operation of a website (e.g., to save logins or other user entries or for security reasons).
• Statistics, marketing, and personalization cookies: Furthermore, cookies are usually also used within the framework of reach measurement and when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles serve, for example, to show users content that corresponds to their potential interests. This process is also referred to as “tracking,” i.e., following the potential interests of users. We inform you separately about the use of “tracking” technologies in our privacy policy or within the framework of obtaining consent.

8.2. We use “session cookies,” which are only stored for the duration of the current visit to our online presence (e.g., to enable the storage of your login status or the shopping cart function and thus the use of our online offering at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offering and, for example, log out or close the browser.

8.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.

8.4. The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the business operation of our online offering and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke consent given or to object to the processing of your data by cookie technologies (“opt-out”). You can first declare your opt-out using the settings of your browser by objecting to the setting of cookies in the system settings of your browser. An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices within the framework of the information on the service providers and cookies used.

Before we process or have data processed within the framework of the use of cookies, we ask users for consent that can be revoked at any time. Until consent has been given, cookies that are necessary for the operation of our online offering are used at most. Their use is based on our interest and the interest of users in the expected functionality of our online offering. This includes usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Users of our online offering are affected by this processing. The processing takes place on the legal basis of consent (Art. 6 para. 1 sentence 1 lit. a GDPR) or legitimate interests within the meaning of Art. 6 para. 1 sentence 1 lit. f. GDPR.

9. Google Analytics

9.1. On the basis of your consent for the analysis, optimization, and economic operation of our online offering, we use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses permanent third-party cookies. The resulting information is processed exclusively in our interest.

9.2. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.

9.3. We have agreed so-called standard contractual clauses with Google in order to be able to ensure an adequate level of data protection. Google thereby provides a guarantee to comply with European data protection law.

9.4. Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services associated with the use of this online offering and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

9.5. We only use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

9.6. The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offering to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

9.7. Further information on data use by Google, setting and objection options can be found on Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“How Google uses data when you use our partners’ sites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.com/settings/ads (“Manage information that Google uses to show you advertising”).

10. Facebook Social Plugins

10.1. On the basis of your consent in the interest of optimization and economic operation of our online offering, we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (e.g., videos, graphics, or text contributions) and are recognizable by one of the Facebook logos or are marked with the addition “Facebook Social Plugin.”

10.2. When a user calls up a function of this online offering that contains such a plugin, a direct connection with Facebook’s servers is only established when the user interacts with the plugins. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering by it. In doing so, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

10.3. By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offering. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example, press the Like button or leave a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

10.4. The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options for protecting the privacy of users, can be found in Facebook’s data protection notices: https://www.facebook.com/about/privacy/.

10.5. If a user is a Facebook member and does not want Facebook to collect data about them via this online offering and link it to their member data stored at Facebook, they must log out of Facebook and delete their cookies before using our online offering. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are adopted for all devices, such as desktop computers or mobile devices.

11. Reach Analysis with Matomo

11.1. On the basis of your consent for the analysis, optimization, and economic operation of our online offering, we use Matomo, an open-source software for the statistical evaluation of user access. The IP address of users is shortened before it is stored. However, Matomo uses first-party cookies that are stored on the users’ computer and enable an analysis of the use of this online offering by users. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

11.2. The information generated by the cookie about your use of this online offering is stored on our server and not passed on to third parties.

12. Newsletter

12.1. With the following information, we inform you about the content of our newsletter as well as the registration, dispatch, and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

12.2. We send newsletters, emails, and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or legal permission. Insofar as the contents of the newsletter are specifically described within the framework of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our products, offers, promotions, and our company.

12.3. Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration, you will receive an email in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with foreign email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

12.4. The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “shipping service provider.” You can view the data protection provisions of the shipping service provider here: https://www.cleverreach.com/en/privacy-policy/.

12.5. The newsletter is sent using “MailChimp,” a newsletter shipping platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection provisions of the shipping service provider here: https://mailchimp.com/legal/privacy/. So-called standard contractual clauses have been agreed upon to ensure an adequate level of data protection.

12.6. Furthermore, according to its own information, the shipping service provider may use this data in pseudonymous form, i.e., without assignment to a user, to optimize or improve its own services, e.g., for technical optimization of shipping and the presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.

12.7. Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for the purpose of personal address in the newsletter.

12.8. The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from the server of the shipping service provider when the newsletter is opened. Within the framework of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our endeavor nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize 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.

12.9. The use of the shipping service provider, performance of statistical surveys and analyses, and logging of the registration process are based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of users.

12.10. You can cancel the receipt of our newsletter at any time, i.e., revoke your consent. This simultaneously expires your consent to its dispatch by the shipping service provider and the statistical analyses. A separate revocation of the dispatch by the shipping service provider or the statistical evaluation is unfortunately not possible. A link to cancel the newsletter can be found at the end of each newsletter. If users have only registered for the newsletter and canceled this registration, their personal data will be deleted.

13. Integration of Videos

13.1. We use videos to display the submitted contributions. Since local hosting of videos is not powerful enough, we rely on external video providers. We use the services of Vimeo, Inc., West 18th Street, New York 10011, USA (“Vimeo”).

13.2. The integration of the videos leads to a call to the provider’s servers. For the associated use of data, we refer to the respective data protection notices of the provider. Vimeo’s data protection notices can be accessed under the following link: https://vimeo.com/privacy.

13.3. The legal basis for the integration of the videos and the associated transmission of personal data for registered users of our offering is Art. 6 para. 1 lit. b GDPR. The integration is necessary because no comparable video solution is currently available to provide protected videos.

13.4. For non-registered users, the legal basis for the transmission of personal data is Art. 6 para. 1 lit f. GDPR.

13.5. In order to ensure an adequate level of data protection when transmitting data to the USA, we have concluded so-called standard contractual clauses with the provider of Vimeo. As a further protective measure, we generally integrate videos in the “Do Not Track” variant, so that the scope of the transmitted personal data is reduced to a minimum.

13.6. Alternatively, we can also use the service provider YouTube. Videos of the platform “YouTube” of the third-party provider Google. In this case, the video is integrated into our website but continues to be hosted on the YouTube platform. When the video is played, a connection is established with YouTube. The privacy policy can be accessed here: https://www.google.com/policies/privacy/ and an opt-out can be found here: https://www.google.com/settings/ads/. With Google we have

14. Integration of Third-Party Services and Content

14.1. Within our online offering, we use content or service offerings from third-party providers on the basis of our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. GDPR) or on the basis of your consent (Art. 6 para. 1 lit. a GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This is done to provide our online offering and to create user-friendliness for our online offering. This always presupposes that the third-party providers of this content perceive the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in third-party cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other details about the use of our online offering, as well as be linked to such information from other sources.

14.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy policies, which contain further information on the processing of data and, in some cases already mentioned here, objection options (so-called opt-out):

• If our customers use the payment services of third parties (e.g., PayPal or Sofortüberweisung), the terms and conditions and the privacy notices of the respective third-party providers apply, which can be accessed within the respective websites or transaction applications.
• External fonts from Google Ireland., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts takes place through a server call at Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/. An opt-out can be found here https://www.google.com/settings/ads/.
• Maps of the service “Google Maps” of the third-party provider Google. The privacy policy can be accessed here: https://www.google.com/policies/privacy/, an opt-out option can be found here: https://www.google.com/settings/ads/
• Our online offering uses functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Every time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click the LinkedIn “Recommend button” and are logged into your LinkedIn account, LinkedIn is able to assign your visit to our website to you and your user account. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. The privacy policy can be accessed here: https://www.linkedin.com/legal/privacy-policy and an opt-out is available here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Functions of the Twitter service may be integrated within our online offering. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter in the process. We point out that we, as the provider of the pages, receive no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy at http://twitter.com/privacy. You can change your privacy settings at Twitter in the account settings at http://twitter.com/account/settings.
• We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Every time one of our pages containing Xing functions is accessed, a connection to Xing servers is established. To our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated. Privacy policy: https://www.xing.com/app/share?op=data_protection.

15. Rights of the Data Subject

If personal data of yours is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:

15.1. Right of access
You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request access to the following information from the controller:

• the purposes for which the personal data is processed;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
• the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage duration;
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
• the existence of a right to lodge a complaint with a supervisory authority;
• all available information about the origin of the data if the personal data is not collected from the data subject;
• the existence of automated decision-making, including profiling, referred to in Art. 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

15.2. Right to rectification
You have a right to rectification and/or completion by the controller if the processed personal data concerning you is inaccurate or incomplete. The controller must carry out the rectification without undue delay.

15.3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of your personal data:

• if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
• the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise, or defense of legal claims; or
• if you have objected to processing pursuant to Art. 21(1) GDPR pending the verification of whether the legitimate grounds of the controller override your grounds.

Where processing of the personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

15.4. Right to erasure
a) Duty to erase
You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay where one of the following grounds applies:

• The personal data concerning you is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
• You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
• The personal data concerning you has been unlawfully processed.
• The personal data concerning you must be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data concerning you was collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

b) Information to third parties
Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17(1) GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions
The right to erasure does not apply to the extent that processing is necessary

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health in accordance with Art. 9(2)(h) and (i) as well as Art. 9(3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89(1) GDPR in so far as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
• for the establishment, exercise, or defense of legal claims.

15.5. Right to information
If you have asserted the right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you has been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients by the controller.

15.6. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided, where

• the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and
• the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This shall not adversely affect the rights and freedoms of others.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

15.7. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions.

The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

15.8. Right to withdraw the data protection consent declaration
You have the right to withdraw your data protection consent declaration at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

15.9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• is necessary for entering into, or performance of, a contract between you and the controller,
• is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
• is based on your explicit consent.

However, these decisions shall not be based on special categories of personal data referred to in Art. 9(1) GDPR, unless Art. 9(2)(a) or (g) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in (1) and (3), the controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

15.10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

16. Erasure of Data

16.1. The data stored by us will be erased as soon as they are no longer required for their intended purpose and there are no statutory retention obligations to the contrary. Erasure also takes place in particular if other legal permissions cease to apply. If the users’ data are not erased because they are required for other and legally permissible purposes, their processing will be restricted, i.e., the data will be blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

16.2. According to legal requirements, storage takes place for 6 years in accordance with Section 257 (1) HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

17. Right to Object

Users may object to the future processing of their personal data at any time in accordance with legal requirements. The objection may be made in particular against processing for the purposes of direct marketing.

18. Changes to the Privacy Policy

18.1. We reserve the right to change the privacy policy in order to adapt it to changed legal situations, or in the event of changes to the service or data processing. However, this only applies with regard to declarations on data processing. If user consent is required or if components of the privacy policy contain regulations of the contractual relationship with the users, the changes will only be made with the users’ consent.

18.2. Users are requested to inform themselves regularly about the content of the privacy policy.