1. General Information on Data Processing and Legal Bases

1.1. This Privacy Policy informs you about the nature, scope, and purpose of the processing of personal data within our online offering and the associated websites, functions, and content (hereinafter collectively referred to as “online offering” or “website”). This Privacy Policy applies regardless of the domains, systems, platforms, and devices used (e.g., desktop or mobile) on which the online offering is accessed.

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

2. Types of Data Processed / Categories of Data Subjects

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

• Master data (e.g., names and addresses of customers),
• Contact data (e.g., email, phone numbers),
• Communication data,
• Contract data (e.g., services used, names of responsible persons, payment information),
• Usage data (e.g., the visited pages of our online offering, interest in our products)
• Meta/communication data (e.g., device information, IP addresses) and
• Content data (e.g., entries in the contact form).

2.2. The term “user” encompasses all categories of data subjects. These include our business partners, customers, prospective customers, and other visitors to our online offering. The terms used are to be understood as gender-neutral.

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

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

2.5. The following persons are affected by data processing:

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

3. Security Measures

3.1. In accordance with Art. 32 GDPR, we implement appropriate organizational, contractual, and technical security measures corresponding to the state of the art, taking into account 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, to ensure a level of security appropriate to the risk. This ensures compliance with data protection laws and protects this data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

3.2. Security measures include, in particular, the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the fact that the URL in your browser’s address bar begins with “https://”. This is a communication protocol that allows data to be transmitted securely against eavesdropping through transport encryption.

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

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

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

4.3. If content, tools, or other means described in this Privacy Policy are used by other providers (hereinafter collectively referred to as “third-party providers”), we comply with legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

4.4. If we use a third-party provider whose registered office is located in a third country (outside the European Union or the European Economic Area), it can be assumed that data will be transferred to the third-party provider’s countries of establishment. Data is only transferred to third countries if an adequate level of data protection, user consent, or another legal permission exists.

5. Provision of Contractual Services

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

5.2. We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for archiving reasons (e.g., for tax purposes, generally 10 years). Data disclosed to us by the contractual partner within the framework of a contractual relationship will generally be deleted by us in accordance with the contract’s provisions after the contractual services have been fulfilled.

6. Contacting Us

6.1. When contacting us (via contact form or email), user information is processed for handling the contact request and its processing pursuant to Art. 6 para. 1 lit. b GDPR. In this process, we only process the data we need to handle your request.

6.2. User information may be stored in our Customer Relationship Management System (“CRM System”) or comparable inquiry organization.

7. Web Hosting

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

7.2. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). Access data includes the name of the retrieved website, 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.

7.3. Log file information is stored for security reasons (e.g., for the clarification of abuse or fraudulent acts) for a maximum of seven days and then deleted. Data whose further retention is required for evidentiary purposes are excluded from deletion until the final clarification of the respective incident.

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

8. Cookies & Audience Measurement

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

• A distinction must be made between cookies set by the website operator when visiting a website (also “first-party cookies”) and cookies set by third-party providers (also “third-party cookies”). We only have technical control over the former cookies. We further differentiate between the following cookies.
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their browser.
• Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user revisits a website. Similarly, user interests used for audience measurement or marketing purposes can be stored in such a cookie.
• Necessary (also: essential or strictly necessary) cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g., to save logins or other user inputs or for security reasons).
• Statistics, marketing, and personalization cookies: Furthermore, cookies are generally also used for audience measurement and when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles serve, for example, to display content to users that matches their potential interests. This process is also referred to as “tracking”, i.e., monitoring the potential interests of users. We inform you separately about the use of “tracking” technologies in our Privacy Policy or when obtaining consent.

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

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

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

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

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

9. Google Analytics

9.1. Based on your consent, we use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), for the analysis, optimization, and economic operation of our online offering. Google uses persistent third-party cookies. The information generated from this is processed exclusively in our interest.

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

9.3. We have agreed on so-called Standard Contractual Clauses with Google to ensure an adequate level of data protection. Google thereby offers a guarantee to comply with European data protection law.

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

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

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

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

10. Facebook Social Plugins

10.1. Based on your consent, and in the interest of optimizing and economically operating our online offering, we use social plugins (“plugins”) from the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g., videos, graphics, or text posts) and are recognizable by a Facebook logo or are marked with the addition “Facebook Social Plugin”.

10.2. When a user accesses a function of this online offering that contains such a plugin, a direct connection to Facebook’s servers is only established if the user interacts with the plugins. The content of the plugin is transmitted directly by Facebook to the user’s device and integrated into the online offering. User profiles can be created from the processed data. Therefore, we have no influence over the scope of data that Facebook collects with the help of this plugin and inform users accordingly to the best of our knowledge.

10.3. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offering. If the user is logged into Facebook, Facebook can associate the visit with their Facebook account. If users interact with the plugins, for example, by clicking the Like button or submitting a comment, the corresponding information is transmitted directly from their device to Facebook and stored there. If a user is not a member of Facebook, there is still a possibility that Facebook will obtain and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

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

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

11. Reach Analysis with Matomo

11.1. Based on your consent, we use Matomo, an open-source software for statistical analysis of user access, to analyze, optimize, and economically operate our online offering. Users’ IP addresses are truncated before being stored. However, Matomo uses first-party cookies, which are stored on users’ computers and enable an analysis of their use of this online offering. Pseudonymous user profiles can be created from the processed data.

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

12. Newsletter

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

12.2. We send newsletters, emails, and other electronic notifications with promotional information (hereinafter “Newsletter”) only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described during registration, it is decisive for the users’ consent. Otherwise, our newsletters contain information about our products, offers, promotions, and our company.

12.3. The registration for our newsletter takes place via a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to prevent anyone from registering with third-party email addresses. Newsletter registrations are logged to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation times, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

12.4. Newsletters are sent via CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “shipping service provider”. You can view the data protection regulations of the shipping service provider here: https://www.cleverreach.com/de/datenschutz/.

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

12.6. Furthermore, according to its own information, the shipping service provider may use this data in pseudonymous form, i.e., without attribution to a user, for the optimization or improvement of its own services, e.g., for the technical optimization of sending and displaying newsletters or for statistical purposes to determine which countries the recipients come from. However, the shipping service provider does not use the data of our newsletter recipients to contact them directly or pass them on to third parties.

12.7. Registration data: To subscribe to the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for personalized addressing in the newsletter.

12.8. The newsletters contain a so-called “web-beacon”, i.e., a pixel-sized file that is retrieved from the shipping service 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, are initially collected. This information is used for the technical improvement of services based on technical data or for understanding target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or access times. 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 assigned to individual newsletter recipients. However, it is neither our intention nor that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

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

12.10. You can unsubscribe from our newsletter at any time, i.e., revoke your consent. This simultaneously revokes your consent to its dispatch by the shipping service provider and to the statistical analyses. Unfortunately, a separate revocation of dispatch by the shipping service provider or statistical evaluation is not possible. You will find a link to unsubscribe from the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and then canceled this subscription, their personal data will be deleted.

13. Integration of Videos

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

13.2. By integrating the videos, the provider’s servers are accessed. For the associated use of data, we refer to the respective data protection notices of the provider. Vimeo’s data protection notices can be found at the following link: https://vimeo.com/privacy/.

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

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

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

13.6. Alternative können wir auch auf den Dienstleister YouTube zurückgreifen. Videos der Plattform “YouTube” des Drittanbieters Google. Hierbei wird das Video in unsere Website eingebunden, aber weiterhin auf der Plattform von Youtube gehostet. Wenn das Video abgespielt wird, erfolgt ein Verbindungsaufbau mit YouTube. Die Datenschutzerklärung ist hier abrufbar: https://www.google.com/policies/privacy/ und eine Opt-Out finden Sie hier: https://www.google.com/settings/ads/.

14. Integration of Third-Party Services and Content

14.1. Within our online offering, based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f GDPR) or based on your consent (Art. 6 para. 1 lit. a GDPR), we use content or service offerings from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “Content”). This is done to provide our online offering and to create user-friendliness for our online offering. This always requires that the third-party providers of this content perceive the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content. We strive 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. Through the “Pixel Tags”, information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in third-party cookies on the users’ device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other details about the use of our online offering, and can also be linked with such information from other sources.

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

• If our customers use third-party payment services (e.g., PayPal or Sofortüberweisung), the terms and conditions and privacy notices of the respective third-party providers apply, which can be accessed within the respective websites or transaction applications.
• External fonts from Google Ireland., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts occurs through a server call to Google (usually in the USA). Privacy Policy: https://www.google.com/policies/privacy/. An opt-out can be found here: https://www.google.com/settings/ads/.
• Maps from the service “Google Maps” of the third-party provider Google. The privacy policy can be found here: https://www.google.com/policies/privacy/, An opt-out option can be found here: https://www.google.com/settings/ads/
• Our online offering uses functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Each time you access one of our pages that contains LinkedIn functions, a connection to LinkedIn’s servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click LinkedIn’s “Recommend button” and are logged into your LinkedIn account, LinkedIn can associate your visit to our website with you and your user account. We point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn. The privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy and an opt-out is available here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Functions of the Twitter service may be integrated within our online offering. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transferred to Twitter in this process. We point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy can be found at http://twitter.com/privacy. You can change your privacy settings on Twitter in the account settings under http://twitter.com/account/settins.
• We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time you access one of our pages that contains XING functions, a connection to XING’s servers is established. To our knowledge, no personal data is stored in this process. In particular, no IP addresses are stored, nor is user behavior evaluated. Privacy Policy: https://www.xing.com/app/share?op=data_protection.

15. Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the GDPR, and you have the following rights vis-à-vis the controller:

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

If such processing exists, you can request information from the controller about the following:

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

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

15.2. Right to Rectification
You have the right to obtain from the controller the rectification and/or completion of inaccurate or incomplete personal data concerning you. The controller shall rectify the data without undue delay.

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

• if you contest the accuracy of your personal data for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
• the controller no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims, or
• if you have objected to processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

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

If the restriction of processing has been imposed pursuant to the above conditions, you will be informed by the controller before the restriction is lifted.

15.4. Right to Erasure
a) Obligation to erase
You may request from the controller that your personal data be erased without undue delay, and the controller is obliged to erase these data without undue delay if one of the following reasons applies:

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

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

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

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

15.5. Right to Notification
If you have exercised your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to communicate this rectification or erasure of data or restriction of processing to all recipients to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to be informed by the controller about these recipients.

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

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

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

The right to data portability shall not apply to 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.

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

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

Where personal data concerning you are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

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

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

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

15.9. Automated Individual Decision-Making, Including Profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision

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

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

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

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

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

16. Deletion of Data

16.1. The data stored by us will be deleted as soon as they are no longer required for their intended purpose and no statutory retention obligations prevent their deletion. Deletion also occurs, in particular, if other grounds for permission cease to exist. If user data are not deleted because they are required for other legally permissible purposes, their processing will be restricted, i.e., the data will be blocked and not processed for other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

16.2. In accordance with legal requirements, data are retained for 6 years pursuant to § 257 (1) HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years pursuant to § 147 (1) AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

17. Right to Object

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

18. Changes to the Privacy Policy

18.1. We reserve the right to amend the Privacy Policy to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this applies only with regard to declarations on data processing. If user consents are required or if components of the Privacy Policy contain provisions of the contractual relationship with users, changes will only be made with the consent of the users.

18.2. Users are requested to regularly inform themselves about the content of the Privacy Policy.