Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the provision of our services and, in particular, on our websites, in mobile applications, and within external online presences such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

As of: 4 October 2026

Table of contents

Controller

  • Company name: Teatown Software, S.L.
  • Registered office: Calle Marqués de Larios 9, 3º izquierda, 29015 Málaga, Spain
  • Tax ID (NIF): B25975335
  • Authorized representative (administrador único): Ing. Lucas Christian Müllner
  • Email: office@teatown.es
  • Registry details: Registered in the Mercantile Registry of Málaga, electronic Volume, electronic Folio, Page ( Hoja) MA-196282, Entry 1ª.

Overview of processing activities

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

Types of data processed

  • Master data
  • Payment data
  • Contact data
  • Content data
  • Contract data
  • Usage data
  • Meta, communication and procedural data
  • Log data

Categories of data subjects

  • Recipients of services and clients
  • Prospective customers
  • Communication partners
  • Users
  • Business and contractual partners

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations
  • Communication
  • Security measures
  • Reach measurement
  • Tracking
  • Office and organizational procedures
  • Audience building
  • Organizational and administrative procedures
  • Feedback
  • Marketing
  • Profiles with user-related information
  • Provision of our online offering and user-friendliness
  • Information technology infrastructure
  • Public relations
  • Business processes and economic procedures

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given their consent to the processing of personal data relating to them for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Spain: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Spain. These include, in particular, Organic Law 3/2018 of 5 December on the Protection of Personal Data and the guarantee of digital rights (Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales – “LOPDGDD”), which supplements and specifies the GDPR, in particular with regard to the rights of data subjects, the legal bases for processing, the processing of data relating to deceased persons, and the digital rights recognized under Spanish law. In addition, Law 34/2002 of 11 July on information society services and electronic commerce (Ley 34/2002, de 11 de julio, de servicios de la sociedad de la información y de comercio electrónico – “LSSI-CE”) applies, in particular to the use of cookies and to electronic commercial communications.

Note on the applicability of the GDPR and the Swiss FADP: This privacy information serves to provide information both under the Swiss Federal Act on Data Protection (FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial scope and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP – “processing” of “personal data,” “overriding interest,” and “particularly sensitive personal data” – the terms used in the GDPR are used, namely “processing” of “ personal data,” “legitimate interest,” and “special categories of data.” However, the legal meaning of the terms continues to be determined under the Swiss FADP within the scope of its applicability.

Security measures

In accordance with legal requirements, and taking into account the state of the art, the cost of implementation, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, disclosure, availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data, and responses to threats to the data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transfer of personal data

In the course of our processing of personal data, it may happen that the data is transferred to, or disclosed to, other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content embedded in a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: Insofar as we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or this occurs in the course of using third-party services or the disclosure or transfer of data to other persons, bodies, or companies (which is recognizable from the postal address of the respective provider or where the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses take effect as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and erasure

We erase personal data that we process in accordance with the legal provisions as soon as the underlying consents are withdrawn or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the pursuit of legal claims or the protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and erasure of data that applies specifically to certain processing operations.

Where multiple retention periods or erasure deadlines apply to a given piece of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose, but rather due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Retention and erasure of data: The following general periods apply under Spanish law to the retention and archiving of personal data, insofar as this is necessary to fulfill legal obligations or to safeguard legitimate interests:

  • 6 years – Personal data processed in connection with commercial books, accounting records, correspondence, documentation, and supporting vouchers relating to the business is retained for six years in accordance with Section 30 of the Spanish Commercial Code (Código de Comercio). The period runs from the date of the last entry made in the books.
  • 4 years – Personal data processed in connection with tax-relevant documentation is retained for the duration of the tax limitation period, which is generally four years in accordance with Section 66 of the General Tax Act (Ley 58/2003, General Tributaria). Longer periods may apply in specific tax situations (for example, the offsetting of negative tax bases), where the tax authorities may review earlier periods.
  • 5 years – Data required to assert, exercise, or defend contractual or other personal claims is stored for the duration of the applicable statutory limitation period. For personal actions without a special term, this is generally five years in accordance with Section 1964 of the Spanish Civil Code (Código Civil), unless longer statutory retention obligations exist.

Commencement of retention periods: Where several of the above periods apply to the same data, the longest period is decisive. The relevant period begins when the triggering event occurs — for example, the last accounting entry, the end of the voluntary tax filing period, or, in the case of ongoing contractual relationships under which data is stored, the point in time at which the contractual relationship ends.

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain access to this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be erased without delay, or alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged, in particular, with a supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement. In Spain, the competent supervisory authority is the Spanish Data Protection Agency (Agencia Española de Protección de Datos – AEPD), C/ Jorge Juan 6, 28001 Madrid, https://www.aepd.es.

Business services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively “contractual partners”), for the initiation, execution, and settlement of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken on request, as well as communication in connection with the respective contractual relationship.

Processing serves, in particular, to fulfill our main and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty issues and other performance disruptions, the processing of withdrawals, terminations of continuing obligations, reversals, refunds, as well as the handling of other contract-related declarations and inquiries. This covers both one-off contracts and ongoing contractual relationships.

In particular, we process master data such as name, address, and, where applicable, company; contact data such as email address and telephone number; contract and performance data such as the subject matter of the contract, contract term, order or transaction number; usage and performance data; payment and billing data; as well as communication contents and histories. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an order.

In addition, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation obligations, and, where applicable, verification and accountability obligations. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as the protection of our business operations and our contractual partners from misuse, threats to data, secrets, and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other agents, insofar as this is necessary for the execution of the contract or to fulfill legal obligations.

Personal data is disclosed to third parties exclusively where this is necessary for the performance of the contract, the implementation of pre-contractual measures, the safeguarding of legitimate interests, or the fulfillment of legal obligations. We provide separate information about any processing beyond this, in particular for marketing purposes, within this privacy policy.

We inform contractual partners which data is required in individual cases at the time of data collection, for example in online forms through appropriate labeling or in personal contact.

Data is erased as soon as it is no longer required for the aforementioned purposes and no legal retention obligations preclude erasure. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted to us in the course of a specific order is erased after completion of the order and expiry of any retention periods, unless there are further legal or contractual obligations to store it.

The legal basis for processing is Art. 6(1)(b) GDPR for the implementation of pre-contractual measures and for the performance of the respective contractual relationship, as well as Art. 6(1)(c) GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, the internal administration and documentation of business operations, the enforcement and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations. These interests consist, in particular, of ensuring secure and legally compliant business operations and safeguarding our entrepreneurial capacity to act.

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., subject matter of the contract, term, customer category).
  • Data subjects: Recipients of services and clients; prospective customers; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and economic procedures.
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.”
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) to enable them to select, acquire, or commission the chosen services or works and related activities, as well as to pay for and make them available or perform them. The required information is identified as such in the context of the order, purchase, or comparable contract conclusion, and includes the information needed for service provision and billing, as well as contact information in order to be able to hold any consultations. Insofar as we gain access to information about end customers, employees, or other persons, we process this in accordance with the legal and contractual requirements; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Provision of the online offering and web hosting

We process users’ data in order to be able 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 device.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); log data (e.g., log files relating to logins or the retrieval of data, or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices ( computers, servers, etc.)); security measures.
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called a “web host”); legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, the volume of data transmitted, notification of successful retrieval, browser type and version, the user’s operating system, the 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 server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server utilization and stability; legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from erasure until the respective incident has been definitively resolved.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); **website: ** https://www.hetzner.com; **privacy policy: ** https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner; **data processing agreement: ** https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner.

Use of cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies may be used for various purposes, such as the functionality, security, and comfort of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with the legal regulations. Where necessary, we obtain users’ consent in advance. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used. Under Spanish law, the use of cookies that are not strictly necessary requires your prior consent in accordance with Section 22.2 of Law 34/2002 (LSSI-CE); our cookie banner allows you to accept, reject, or configure non-essential cookies, with rejecting them being as straightforward as accepting them, in line with the guidance of the Spanish Data Protection Agency (AEPD).

Notes on the data protection legal bases: Whether we process personal data by means of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, 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 offering and closed their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, the user data collected by means of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw the consent they have given at any time and also object to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); consent (Art. 6(1)(a) GDPR).

Further information on processing operations, procedures, and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution through which users’ consent to the use of cookies, or to the procedures and providers named within the consent management solution, is obtained. This procedure serves to obtain, log, manage, and withdraw consent, in particular with regard to the use of cookies and comparable technologies used to store, read, and process information on users’ devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option to manage and withdraw their consents. The consent declarations are stored in order to avoid having to request consent again and to be able to provide evidence of consent in accordance with the legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information is provided about the providers of consent management services, the following general information applies: the consent is stored for up to two years. In doing so, a pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, the system, and the device used; legal bases: Consent (Art. 6(1)(a) GDPR).

Contact and inquiry management

When you contact us (e.g., by post, contact form, email, telephone, or via social media), as well as within the framework of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries and any requested measures.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as the information relating to them, such as details of authorship or time of creation); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via an online form); provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual inquiries ( Art. 6(1)(b) GDPR).

Further information on processing operations, procedures, and services:

  • Contact form: When you contact us via our contact form, by email, or through other communication channels, we process the personal data transmitted to us in order to respond to and handle the respective request. This generally includes information such as name, contact information, and, where applicable, further information communicated to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of making contact and communicating; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Web analytics, monitoring and optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify when our online offering or its functions or content are most frequently used, or invite reuse. Likewise, it enables us to understand which areas require optimization.

In addition to web analytics, we may also use testing procedures, for example to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles—i.e., data combined into a usage operation—may be created for these purposes, and information may be stored in a browser or on a device and then read out. The information collected includes, in particular, visited websites and the elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. Insofar as users have consented to the collection of their location data vis-à-vis us or the providers of the services we use, the processing of location data is also possible.

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization; instead, pseudonyms are used. This means that we, as well as the providers of the software used, do not know the actual identity of users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., an interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.” Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Customer reviews and rating procedures

We participate in review and rating procedures in order to evaluate, optimize, and promote our services. When users rate us via the participating rating platforms or procedures, or otherwise provide feedback, the general terms and conditions or terms of use and the privacy notices of the providers additionally apply. As a rule, rating also requires registration with the respective providers.

To ensure that the rating persons have actually made use of our services, we transmit the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, email address, and order or item number), with the customer’s consent. This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Recipients of services and clients; users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via an online form); marketing.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Rating widget: We embed so-called “rating widgets” in our online offering. A widget is a functional and content element embedded in our online offering that displays variable information. It may be presented, for example, in the form of a seal or comparable element, sometimes also called a “badge.” The corresponding content of the widget is displayed within our online offering, but at that moment it is retrieved from the servers of the respective widget provider. Only in this way can the current content always be shown, in particular the respective current rating. For this, a data connection must be established from the web page accessed within our online offering to the server of the widget provider, and the widget provider receives certain technical data (access data, including the IP address) that is necessary for the content of the widget to be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offerings participating in the rating procedure have been visited by the user. The information can be stored in a user profile and used for advertising or market research purposes; * legal bases:* Legitimate interests (Art. 6(1)(f) GDPR).

Presence on social networks (social media)

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

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

Furthermore, users’ data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on users’ usage behavior and the resulting interests. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to users’ interests. For this reason, cookies are generally stored on users’ computers in which the usage behavior and interests of users are stored. In addition, data may be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and logged in there).

For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information of the operators of the respective networks.

Also in the case of requests for access and the exercise of data subjects’ rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the users’ data and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; feedback (e.g., collecting feedback via an online form); public relations.
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection ( but not the further processing) of visitor data used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles such as job function, country, industry, seniority level, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which regulates, in particular, which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct access or erasure requests directly to LinkedIn). Users’ rights (in particular the right of access, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of the data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of the data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); **website: ** https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/privacy-policy). **Opt-out option: ** https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); *privacy policy: ** https://business.safety.google/privacy/; basis for third-country transfers: Data Privacy Framework (DPF). * Opt-out option: https://myadcenter.google.com/.

Plug-ins and embedded functions and content

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

The embedding always requires that the third-party providers of this content process the user’s IP address, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functions. We endeavor to use only such 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. By means of 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 cookies on the user’s device and may contain, among other things, technical information about the browser and the operating system, referring websites, the time of the visit, and further information about the use of our online offering, as well as being linked to such information from other sources.

Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for the data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., an interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); audience building; marketing; profiles with user-related information (creation of user profiles).
  • Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure.” Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • LinkedIn plug-ins and content: These may include, for example, content such as images, videos, or text and buttons with which users can share content of this online offering within LinkedIn; service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; legal bases: Consent (Art. 6(1)(a) GDPR); **website: ** https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; data processing agreement: https://de.linkedin.com/legal/l/dpa; basis for third-country transfers: Data Privacy Framework ( DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/l/dpa). **Opt-out option: ** https://www.linkedin.com/mypreferences/g/guest-retargeting-opt-out.
  • MyFonts: Fonts; the data processed in the course of retrieving fonts: the identification number of the web font project (anonymized), the URL of the licensed website, which is linked to a customer number in order to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days in order to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.myfonts.com; **privacy policy: ** https://www.myfonts.com/de/a/font/legal/website-use-privacy-policy.
  • YouTube videos: Video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6(1)(a) GDPR); website: https://www.youtube.com; *privacy policy: ** https://business.safety.google/privacy/; basis for third-country transfers: Data Privacy Framework (DPF). * Opt-out option: opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
  • YouTube videos: Videos stored on YouTube are embedded within our online offering. The integration of these YouTube videos takes place via a special domain using the “youtube-nocookie” component in the so-called “extended data protection mode.” In “extended data protection mode,” only information including your IP address and details about your browser and device can be stored on your device in cookies or by means of comparable procedures until the video is started, which YouTube requires for the output, control, and optimization of the video display. As soon as you play the videos, additional information for the analysis of usage behavior and for storage in the user profile and for the personalization of content and advertisements may be processed by YouTube. The storage period for the cookies can be up to two years; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6(1)(a) GDPR); website: https://www.youtube.com; **privacy policy: ** https://business.safety.google/privacy/; basis for third-country transfers: Data Privacy Framework (DPF). * *Further information: ** https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Cerweiterten-datenschutzmodus-aktivieren.

Amendment and update

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the information before making contact.

Definitions of terms

In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are intended primarily to aid understanding.

Master data: Master data comprises essential information required for the identification and administration of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions, or systems, by enabling unambiguous assignment and communication.

Content data: Content data comprises information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, authorship information, and publication dates.

Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.

Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, comprises information describing the context, origin, and structure of other data. It can include details on file size, creation date, the author of a document, and modification histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.

Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data comprises a broad range of information that shows how users use applications, which functions they prefer, how long they remain on certain pages, and which paths they take through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences, and possible problem areas within digital offerings.

Personal data: “Personal data” means any information relating to an identified or identifiable natural person ( hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier ( e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Profiles with user-related information: The processing of “profiles with user-related information,” or “profiles” for short, comprises any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.

Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.

Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, identify when users visit their web pages and which content they are interested in. This enables them, for example, to better adapt the content of the web pages to the needs of their visitors.

Tracking: “Tracking” refers to the ability to trace the behavior of users across multiple online offerings. As a rule, behavioral and interest information relating to the online offerings used is stored in cookies or on the servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.

Controller: “Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processing: “Processing” is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collecting, evaluating, storing, transmitting, or erasing it.

Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include the start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options, and special terms or clauses. It serves as the legal basis for the relationship between the parties and is decisive for clarifying rights and obligations, enforcing claims, and resolving disputes.

Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of decisive importance for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and billing information. Payment data can also include information about the payment status, chargebacks, authorizations, and fees.

Audience building: Audience building (in English, “custom audiences”) refers to the determination of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike audiences” (or similar target groups), in turn, refers to content deemed suitable being shown to users whose profiles or interests presumably correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purposes of building custom audiences and lookalike audiences.