Data Privacy

# Privacy Policy

## Types of Data Processed

- Inventory data (e.g., personal master data, names, or addresses).

- Contact data (e.g., email, telephone numbers).

- Content data (e.g., text input, photographs, videos).

- Usage data (e.g., websites visited, interest in content, access times).

- Meta/communication data (e.g., device information, IP addresses).

## Categories of Data Subjects

Visitors and users of the online offering (hereinafter, we also collectively refer to the data subjects as "users").

## Purpose of Processing

- Provision of the online offering, its functions, and content.

- Responding to contact inquiries and communicating with users.

- Security measures.

- Reach measurement/marketing.

## Terminology Used

"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. a cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually every handling of data.

"Pseudonymization" means the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

"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.

"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

## Relevant Legal Bases

In accordance with Art. 13 GDPR, we inform you of the legal bases for our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEA, the following applies unless the legal basis is stated elsewhere in this privacy policy:

- The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR.

- The legal basis for processing to perform our services and carry out contractual measures, as well as to respond to inquiries, is Art. 6(1)(b) GDPR.

- The legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) GDPR.

- Should vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.

- The legal basis for processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6(1)(e) GDPR.

- The legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR.

- The processing of data for purposes other than those for which it was collected is governed by the provisions of Art. 6(4) GDPR.

- The processing of special categories of data (pursuant to Art. 9(1) GDPR) is governed by the provisions of Art. 9(2) GDPR.

## Security Measures

In accordance with legal requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take 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 access to the data as well as access to, entry of, and disclosure of that data, ensuring its availability, and its separation. We have furthermore established procedures to ensure the exercise of data subject rights, the deletion of data, and appropriate responses to any compromise of data. We also take the protection of personal data into account during the development and selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and privacy-friendly default settings.

## Cooperation with Processors, Joint Controllers, and Third Parties

To the extent that we disclose data to other persons and companies (processors, joint controllers, or third parties) in the course of our processing, transfer data to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract), if users have consented, if a legal obligation provides for it, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose, transfer, or otherwise grant access to data to other companies within our corporate group, this is done in particular for administrative purposes as a legitimate interest, and beyond that on a basis consistent with legal requirements.

## Transfers to Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA), or Switzerland), or if this occurs in the context of using third-party services or disclosing or transferring data to other persons or companies, this will only be done if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only where the legal requirements are met. This means processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection equivalent to that of the EU, or compliance with officially recognized specific contractual obligations.

## Rights of Data Subjects

You have the right to request confirmation as to whether relevant data is being processed, and to obtain information about that data as well as further information and a copy of the data in accordance with legal requirements.

You have, in accordance with legal requirements, the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with legal requirements, you have the right to request that data concerning you be deleted without delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be handed over to you in accordance with legal requirements, and to request its transfer to other controllers.

You furthermore have the right, in accordance with legal requirements, to lodge a complaint with the competent supervisory authority.

## Right of Withdrawal

You have the right to withdraw consent already given, with effect for the future.

## Right to Object

You may object at any time to the future processing of data concerning you, in accordance with legal requirements. The objection may, in particular, be made against processing for direct marketing purposes.

## Cookies and Right to Object to Direct Marketing

"Cookies" are small files stored on users' computers. Various pieces of information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. "Temporary" cookies, or "session cookies" or "transient cookies," are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie may, for example, store the contents of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent." For instance, the login status can be saved if users visit again after several days. Likewise, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie. "Third-party cookies" are cookies offered by providers other than the controller operating the online offering (otherwise, if they are only the controller's own cookies, they are referred to as "first-party cookies").

We may use temporary and permanent cookies, and we provide clarification on this within our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional limitations of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, particularly in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings. Please note that in this case, not all functions of this online offering may be usable.

## Deletion of Data

The data we process is deleted or its processing restricted in accordance with legal requirements. Unless expressly stated within this privacy policy, the data stored with us will be deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent deletion.

If data is not deleted because it is required for other legally permitted purposes, its processing will be restricted. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

## Changes and Updates to the Privacy Policy

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 we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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## Business-Related Processing

In addition, we process:

- Contract data (e.g., subject matter of the contract, term, customer category).

- Payment data (e.g., bank details, payment history)

of our customers, prospective customers, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

## Order Processing in the Online Shop and Customer Account

We process our customers' data in the course of the ordering process in our online shop, to enable them to select and order chosen products and services, as well as their payment and delivery, or performance.

The processed data includes inventory data, communication data, contract data, and payment data, and the data subjects affected by the processing include our customers, prospective customers, and other business partners. The processing takes place for the purpose of providing contractual services within the scope of operating an online shop, billing, delivery, and customer service. In this context, we use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

The processing takes place to fulfil our services and carry out contractual measures (e.g. processing orders) and to the extent legally required (e.g. legally required archiving of business transactions for commercial and tax purposes). Information marked as required is necessary for entering into and fulfilling the contract. We disclose data to third parties only within the context of delivery, payment, or on the basis of legal permissions and obligations, as well as where this is done on the basis of our legitimate interests, of which we inform you within this privacy policy (e.g., toward legal and tax advisors, financial institutions, freight companies, and authorities).

Users can optionally create a user account, allowing them to view their orders, among other things. As part of registration, the required mandatory information is communicated to users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data relating to that account will be deleted, subject to its retention being necessary for commercial or tax law reasons. Information in the customer account remains until deleted, followed by archiving in the event of a legal obligation or our legitimate interests (e.g., in the event of legal disputes). It is the users' responsibility to back up their data before the end of the contract in the event of termination.

In the course of registration and renewed logins, as well as use of our online services, we store the IP address and the time of the respective user action. This storage takes place on the basis of our legitimate interests, as well as the users' interest in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is required to pursue our legal claims as a legitimate interest, or there is a legal obligation to do so.

Deletion occurs after the expiry of statutory warranty and other contractual rights or obligations (e.g., payment claims or performance obligations arising from contracts with customers), whereby the need to retain the data is reviewed every three years; in the case of retention due to statutory archiving obligations, deletion occurs after these have expired.

## Agency Services

We process our clients' data within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.

In this context, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), and usage and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). We do not generally process special categories of personal data, unless these are part of a commissioned processing task. Data subjects include our customers, prospective customers, and their customers, users, website visitors, or employees, as well as third parties. The purpose of the processing is the provision of contractual services, billing, and our customer service. The legal bases for the processing arise from Art. 6(1)(b) GDPR (contractual services) and Art. 6(1)(f) GDPR (analysis, statistics, optimization, security measures). We process data that is necessary to establish and fulfil contractual services and point out the necessity of providing it. Disclosure to external parties only takes place if it is required within the context of an order. When processing data provided to us within the context of an order, we act in accordance with the instructions of the client, as well as the statutory requirements for processing on behalf of a controller pursuant to Art. 28 GDPR, and do not process the data for any purposes other than those specified in the order.

We delete the data after the expiry of statutory warranty and comparable obligations. The need to retain the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after these have expired (6 years pursuant to Section 257(1) of the German Commercial Code (HGB), 10 years pursuant to Section 147(1) of the German Fiscal Code (AO)). In the case of data disclosed to us by the client within the scope of an order, we delete the data in accordance with the requirements of the order, generally after the order has ended.

## Therapeutic Services and Coaching

We process the data of our clients, prospective clients, and other principals or contractual partners (collectively referred to as "clients") in accordance with Art. 6(1)(b) GDPR, in order to provide our contractual or pre-contractual services to them. The data processed in this context, as well as the nature, scope, purpose, and necessity of its processing, are determined by the underlying contractual relationship. The processed data generally includes clients' master and inventory data (e.g., name, address, etc.), as well as contact data (e.g., email address, phone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), and payment data (e.g., bank details, payment history, etc.).

Within the scope of our services, we may also process special categories of data pursuant to Art. 9(1) GDPR, in particular information on clients' health, potentially relating to their sex life or sexual orientation, ethnic origin, or religious or philosophical beliefs. For this purpose, where necessary, we obtain the express consent of clients pursuant to Art. 6(1)(a), Art. 7, and Art. 9(2)(a) GDPR, and otherwise process such special categories of data for purposes of preventive healthcare on the basis of Art. 9(2)(h) GDPR and Section 22(1) No. 1(b) of the German Federal Data Protection Act (BDSG).

To the extent necessary for contract fulfilment or legally required, we disclose or transfer clients' data in the context of communication with other professionals, third parties necessarily or typically involved in fulfilling the contract, such as billing agencies or comparable service providers, if this serves the provision of our services pursuant to Art. 6(1)(b) GDPR, is legally required pursuant to Art. 6(1)(c) GDPR, serves our interests or those of the clients in efficient and cost-effective healthcare as a legitimate interest pursuant to Art. 6(1)(f) GDPR, or is necessary pursuant to Art. 6(1)(d) GDPR to protect the vital interests of the client or another natural person, or within the scope of consent pursuant to Art. 6(1)(a), Art. 7 GDPR.

Data is deleted once it is no longer required to fulfil contractual or statutory duty-of-care obligations and to handle any warranty and comparable obligations, whereby the need for retention is reviewed every three years; otherwise, statutory retention obligations apply.

## Contractual Services

We process the data of our contractual partners and prospective clients, as well as other principals, customers, mandators, clients, or contractual partners (collectively referred to as "contractual partners") in accordance with Art. 6(1)(b) GDPR, in order to provide our contractual or pre-contractual services to them. The data processed in this context, as well as the nature, scope, purpose, and necessity of its processing, are determined by the underlying contractual relationship.

The processed data includes our contractual partners' master data (e.g., names and addresses), contact data (e.g. email addresses and telephone numbers), as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

We do not generally process special categories of personal data, unless these are part of a commissioned or contractually agreed processing task.

We process data that is necessary to establish and fulfil the contractual services, and point out the necessity of providing it to contractual partners where this is not otherwise evident. Disclosure to external persons or companies only occurs if it is required within the context of a contract. When processing data provided to us within the context of an order, we act in accordance with the instructions of the client as well as statutory requirements.

In the course of using our online services, we may store the IP address and the time of the respective user action. This storage takes place on the basis of our legitimate interests, as well as users' interests in protection against misuse and other unauthorized use. This data is generally not passed on to third parties, unless required to pursue our claims pursuant to Art. 6(1)(f) GDPR, or there is a legal obligation to do so pursuant to Art. 6(1)(c) GDPR.

Data is deleted once it is no longer required to fulfil contractual or statutory duty-of-care obligations and to handle any warranty and comparable obligations, whereby the need for retention is reviewed every three years; otherwise, statutory retention obligations apply.

## External Payment Service Providers

We use external payment service providers via whose platforms users and we can carry out payment transactions (e.g., with links to their respective privacy policies: PayPal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)).

Within the scope of contract fulfilment, we use payment service providers on the basis of Art. 6(1)(b) GDPR. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR, in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as contract-, amount-, and recipient-related information. This information is necessary to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means we do not receive any account- or credit-card-related information, only confirmation or denial of payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit reporting agencies. This transmission serves the purpose of identity and creditworthiness verification. For this, we refer to the terms and conditions and privacy notices of the payment service providers.

The general terms and conditions and privacy notices of the respective payment service providers apply to payment transactions, and can be accessed on their respective websites or transaction applications. We also refer to these for further information and to exercise rights of withdrawal, access, and other data subject rights.

## Administration, Financial Accounting, Office Organization, Contact Management

We process data within the scope of administrative tasks and organizing our business, financial accounting, and compliance with statutory obligations, such as archiving. In this context, we process the same data we process in the course of providing our contractual services. The legal bases for processing are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Customers, prospective customers, business partners, and website visitors are affected by this processing. The purpose of and our interest in the processing lies in administration, financial accounting, office organization, and archiving of data, i.e., tasks that serve to maintain our business operations, perform our tasks, and provide our services. Deletion of data relating to contractual services and contractual communication corresponds to the information provided for those processing activities.

We disclose or transfer data to tax authorities, advisors such as tax advisors or auditors, as well as other billing offices and payment service providers.

Furthermore, on the basis of our business management interests, we store information on suppliers, event organizers, and other business partners, e.g. for the purpose of future contact. We generally store this mostly company-related data permanently.

## Business Analytics and Market Research

To be able to operate our business economically, recognize market trends, and identify the wishes of our contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6(1)(f) GDPR, with data subjects including contractual partners, prospective customers, customers, visitors, and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing, and market research. In doing so, we may take into account the profiles of registered users with information, e.g., on services they have used. The analyses help us increase user-friendliness, optimize our offering, and improve our business management. The analyses are solely for our own use and are not disclosed externally, unless they are anonymous analyses with aggregated values.

To the extent these analyses or profiles are personal, they are deleted or anonymized upon termination by users, otherwise after two years from conclusion of the contract. Otherwise, overall business analyses and general trend determinations are, where possible, carried out anonymously.

## Participation in Affiliate Partner Programs

Within our online offering, on the basis of our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering) pursuant to Art. 6(1)(f) GDPR, we use industry-standard tracking measures to the extent necessary for the operation of the affiliate system. Below, we clarify the technical background for users.

Services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, where, for example, links or third-party services are offered following a contract conclusion). The operators of the respective websites receive a commission when users follow the affiliate links and subsequently make use of the offers.

In summary, it is necessary for our online offering that we can track whether users who are interested in affiliate links and/or the offers available with us subsequently make use of the offers, as a result of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented with certain values, which may be part of the link or set elsewhere, e.g. in a cookie. These values include, in particular, the originating website (referrer), time, an online identifier for the operator of the website on which the affiliate link was found, an online identifier for the respective offer, an online identifier for the user, as well as tracking-specific values such as advertising medium ID, partner ID, and categorizations.

The online identifiers of users that we use are pseudonymous values. This means the online identifiers themselves do not contain personal data such as names or email addresses. They only help us determine whether the same user who clicked on an affiliate link or expressed interest in an offer via our online offering subsequently made use of the offer, i.e., e.g., entered into a contract with the provider. However, the online identifier is personal data insofar as the partner company, and also we, have the online identifier together with other user data. Only in this way can the partner company inform us whether that user made use of the offer and we can, for example, pay out the bonus.

## Amazon Partner Program

On the basis of our legitimate interests (i.e., interest in the economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR), we participate in the Amazon EU partner program, which is designed to provide a medium for websites through which advertising revenue can be earned by placing advertisements and links to Amazon.de (so-called affiliate system). This means that, as an Amazon partner, we earn from qualified purchases.

Amazon uses cookies to be able to trace the origin of orders. Among other things, Amazon can recognize that you clicked the partner link on this website and subsequently purchased a product from Amazon.

Further information on data use by Amazon and options to object can be found in the company's privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.

Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliated companies.

## Digistore24 Partner Program

On the basis of our legitimate interests (i.e., interest in the economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR), we participate in the partner program of Digistore24 GmbH, St.-Godehard-Straße 32, 31139 Hildesheim, Germany, which is designed to provide a medium for websites through which advertising revenue can be earned by placing advertisements and links to Digistore24 (so-called affiliate system). Digistore24 uses cookies to be able to trace the origin of contract conclusions. Among other things, Digistore24 can recognize that you clicked the partner link on this website and subsequently concluded a contract with or via Digistore24.

Further information on data use by Digistore24 and options to object can be found in the company's privacy policy: https://www.digistore24.com/page/privacyl.

## Privacy Notice for the Application Process

We process applicant data solely for the purpose of and within the framework of the application process, in accordance with legal requirements. The processing of applicant data takes place to fulfil our (pre-)contractual obligations within the application process within the meaning of Art. 6(1)(b) GDPR and Art. 6(1)(f) GDPR, to the extent that data processing becomes necessary for us, e.g. in the context of legal proceedings (in Germany, Section 26 BDSG additionally applies).

The application process requires applicants to provide us with their applicant data. The necessary applicant data, if we offer an online form, is indicated; otherwise it follows from the job descriptions and generally includes personal details, postal and contact addresses, and the documents belonging to the application, such as a cover letter, CV, and references. In addition, applicants may voluntarily provide us with additional information.

By submitting an application to us, applicants agree to the processing of their data for purposes of the application process, in accordance with the nature and scope set out in this privacy policy.

To the extent that special categories of personal data within the meaning of Art. 9(1) GDPR are voluntarily communicated within the application process, their processing additionally takes place pursuant to Art. 9(2)(b) GDPR (e.g. health data, such as severe disability status or ethnic origin). To the extent that special categories of personal data within the meaning of Art. 9(1) GDPR are requested from applicants within the application process, their processing additionally takes place pursuant to Art. 9(2)(a) GDPR (e.g. health data, if this is required for the performance of the job).

If made available, applicants can submit their applications to us via an online form on our website. The data is transmitted to us encrypted in accordance with the state of the art.

Applicants may also submit their applications to us via email. In this case, however, we ask that you note that emails are generally sent unencrypted, and applicants must ensure encryption themselves. We therefore cannot accept any responsibility for the transmission path of the application between the sender and receipt on our server, and therefore recommend using an online form or postal mail instead. As an alternative to applying via the online form and email, applicants also have the option of sending us their application by post.

The data provided by applicants may, in the event of a successful application, be further processed by us for the purposes of the employment relationship. Otherwise, if an application for a job posting is unsuccessful, the applicants' data will be deleted. Applicants' data will likewise be deleted if an application is withdrawn, which applicants are entitled to do at any time.

Deletion takes place, subject to any legitimate objection by applicants, after a period of six months has elapsed, so that we can answer any follow-up questions regarding the application and meet our documentation obligations under equal treatment legislation. Invoices for any travel expense reimbursement are archived in accordance with tax law requirements.

## Registration Function

Users can create a user account. As part of registration, the required mandatory information is communicated to users and processed on the basis of Art. 6(1)(b) GDPR for the purposes of providing the user account. The processed data includes, in particular, login information (name, password, and an email address). The data entered as part of registration is used for the purposes of using the user account and its purpose.

Users may be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to any statutory retention obligation. It is the users' responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all data of the user stored during the contract period.

In the course of using our registration and login functions, as well as use of the user account, we store the IP address and the time of the respective user action. This storage takes place on the basis of our legitimate interests, as well as users' interests in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless required to pursue our claims, or there is a legal obligation to do so pursuant to Art. 6(1)(c) GDPR. IP addresses are anonymized or deleted after 7 days at the latest.

## Contacting Us

When contacting us (e.g. via contact form, email, telephone, or social media), the user's information is processed to handle the contact request and its resolution pursuant to Art. 6(1)(b) GDPR (in the context of contractual/pre-contractual relationships) and Art. 6(1)(f) GDPR (other inquiries). Users' information may be stored in a customer relationship management ("CRM") system or a comparable inquiry organization system.

We delete inquiries once they are no longer required. We review the necessity every two years; furthermore, statutory archiving obligations apply.

## Newsletter

With the following notices, we inform you about the content of our newsletter as well as the registration, sending, and statistical evaluation procedures, and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.

**Content of the newsletter:** We send newsletters, emails, and other electronic notifications containing promotional information (hereinafter "newsletter") only with the recipients' consent or a legal permission. To the extent that the content of a newsletter is specifically described as part of a sign-up, it is decisive for users' consent. Otherwise, our newsletters contain information about our services and us.

**Double opt-in and logging:** Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time, as well as the IP address. Changes to your data stored with the sending service provider are likewise logged.

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

The sending of the newsletter and the associated measurement of success take place on the basis of the recipients' consent pursuant to Art. 6(1)(a), Art. 7 GDPR in conjunction with Section 7(2) No. 3 of the German Act Against Unfair Competition (UWG), or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6(1)(f) GDPR in conjunction with Section 7(3) UWG.

The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR. Our interest is directed toward the use of a user-friendly and secure newsletter system that serves both our business interests and meets users' expectations, and also allows us to provide proof of consent.

**Cancellation/withdrawal:** You may cancel receipt of our newsletter at any time, i.e., withdraw your consent. A link to cancel the newsletter can be found at the end of every newsletter. We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove previously given consent. Processing of this data is limited to the purpose of potential defense against claims. An individual request for deletion is possible at any time, provided the former existence of consent is simultaneously confirmed.

## Newsletter – Sending Service Provider

The newsletter is sent using the sending service provider [NAME, ADDRESS, COUNTRY]. You can view the sending service provider's privacy policy here: [LINK TO PRIVACY POLICY]. The sending service provider is used on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR and a data processing agreement pursuant to Art. 28(3) sentence 1 GDPR.

The sending service provider may use recipients' data in pseudonymous form, i.e., without attribution to a user, to optimize or improve its own services, e.g. for technical optimization of sending and display of the newsletter, or for statistical purposes. However, the sending service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

## Newsletter – Success Measurement

The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server, or, if we use a sending service provider, from that provider's server, when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval, is 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 using the IP address) or access times. The statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be attributed to individual newsletter recipients. However, it is neither our intention, nor that of the sending service provider (if used), to observe individual users. Rather, the evaluations serve to help us recognize our users' reading habits and adapt our content to them, or send different content according to our users' interests.

Unfortunately, it is not possible to separately object to success measurement; in this case, the entire newsletter subscription must be cancelled.

## Hosting and Email Sending

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email sending, security services, and technical maintenance services, which we use for the purpose of operating this online offering.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, prospective customers, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

## Collection of Access Data and Log Files

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR. Access data includes the name of the website retrieved, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

For security reasons (e.g. to investigate misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the incident in question has been finally clarified.

## Google Analytics

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(1)(f) GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about use of the online offering by users is generally transmitted to and stored on a Google server in the USA.

Google is certified under the Privacy Shield agreement, thereby providing a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

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

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

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies through appropriate settings in their browser software; users can also prevent the collection of data generated by the cookie and related to their use of the online offering from being sent to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data use by Google, and options for settings and objection, can be found in Google's privacy policy (https://policies.google.com/privacy), as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Users' personal data is deleted or anonymized after 14 months.

## Google AdSense with Personalized Ads

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(1)(f) GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

Google is certified under the Privacy Shield agreement, thereby providing a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the AdSense service, with the help of which ads are displayed on our website, and for the display or other use of which we receive compensation. For these purposes, usage data such as clicks on an ad and users' IP addresses are processed, with the last two digits of the IP address being removed. Users' data is therefore processed in pseudonymized form.

We use AdSense with personalized ads. In doing so, Google draws conclusions about users' interests based on the websites visited or apps used and the resulting user profiles. Advertisers use this information to tailor their campaigns to these interests, which benefits both users and advertisers. For Google, ads are personalized when collected or known data determines or influences ad selection. This includes, among other things, previous search queries, activities, website visits, app usage, demographic and location information. Specifically, this includes: demographic targeting, interest category targeting, remarketing, and targeting on customer match lists and audience lists uploaded to DoubleClick Bid Manager or Campaign Manager.

Further information on data use by Google, and options for settings and objection, can be found in Google's privacy policy (https://policies.google.com/technologies/ads), as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

## Facebook Pixel, Custom Audiences, and Facebook Conversion

Within our online offering, on the basis of our legitimate interests in the analysis, optimization, and economic operation of our online offering, and for these purposes, we use the so-called "Facebook Pixel" of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").

Facebook is certified under the Privacy Shield agreement, thereby providing a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook Pixel, Facebook is able, on the one hand, to determine visitors to our online offering as a target group for the display of ads (so-called "Facebook Ads"). Accordingly, we use the Facebook Pixel to only show the Facebook Ads placed by us to those Facebook users who have shown an interest in our online offering, or who exhibit certain characteristics (e.g. interests in certain topics or products, determined based on the websites visited), which we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to users' potential interest and do not feel intrusive. With the help of the Facebook Pixel, we can further track the effectiveness of Facebook advertisements for statistical and market research purposes, by seeing whether users were redirected to our website after clicking a Facebook ad (so-called "conversion").

The processing of data by Facebook takes place within the framework of Facebook's data usage policy. Accordingly, general information on the display of Facebook Ads can be found in Facebook's data usage policy: https://www.facebook.com/policy. Specific information and details about the Facebook Pixel and how it works can be found in Facebook's help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection by the Facebook Pixel and the use of your data to display Facebook Ads. To set which types of ads are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions on settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

You can further object to the use of cookies for reach measurement and advertising purposes via the opt-out page of the Network Advertising Initiative (http://optout.networkadvertising.org/), and additionally via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

*Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke*