Privacy Policy

Last updated: 1 September 2026

This is a translation provided for convenience. The German version is the legally binding text; in case of any discrepancy, the German wording prevails. References to statutes are to German law.

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

The terms used are not gender-specific.

Table of contents

• Controller
• Overview of processing operations
• Relevant legal bases
• Security measures
• Transfer of personal data
• International data transfers
• General information on data storage and erasure
• Rights of data subjects
• Reach measurement (Vercel Web Analytics)
• Embedded videos (YouTube)
• Language preference in browser storage
• Business services
• Business processes and procedures
• Provision of the online offering and web hosting
• Contact and enquiry management
• Artificial intelligence (AI)
• Cloud services
• Newsletter and electronic notifications
• Presence on social networks (social media)
• Management, organisation and support tools
• Amendment and updating
• Competent supervisory authority
• Definitions of terms

Controller

Kai Hackbarth, Hagener Straße 67, 58285 Gevelsberg, Germany

Email address: kai@kaihackbarth.com

Telephone: +49 176 45151099

Legal notice: kaihackbarth.com/imprint

Overview of processing operations

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

Types of data processed

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

Categories of data subjects

• Recipients of services and clients.
• Prospective clients.
• Communication partners.
• Users.
• Business and contractual partners.
• Clients.
• Third parties.

Purposes of processing

• Provision of contractual services and fulfilment of contractual obligations.
• Communication.
• Security measures.
• Direct marketing.
• Reach measurement.
• Office and organisational procedures.
• Organisational and administrative procedures.
• Feedback.
• Marketing.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Financial and payment management.
• Public relations.
• Sales promotion.
• Business processes and commercial procedures.
• Artificial intelligence (AI).

Relevant legal bases

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

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

National data protection provisions in Germany: In addition to the data protection provisions of the GDPR, national data protection rules apply in Germany. These include in particular the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The BDSG contains special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases including profiling. Data protection acts of the individual federal states may also apply.

Security measures

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

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

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

Transfer of personal data

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

International data transfers

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

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

This twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as additional security. Should changes arise in the context of the DPF, the standard contractual clauses take effect as a reliable fallback. In this way we ensure that your data remains adequately protected even in the event of political or legal changes.

For each individual service provider we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: European Commission, international dimension of data protection.

General information on data storage and erasure

We erase personal data that we process in accordance with the statutory provisions as soon as the underlying consent is withdrawn or no further legal bases for the processing exist. This concerns cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply where statutory obligations or particular interests require longer retention or archiving of the data.

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

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

Where there are several specifications regarding the retention period or erasure deadlines for a data item, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but on account of statutory requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and erasure of data: The following general periods apply to retention and archiving under German law:

• 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organisational documents required for their understanding (Section 147(1) no. 1 in conjunction with (3) AO, Section 257(1) no. 1 in conjunction with (4) HGB).
• 8 years – accounting vouchers, such as invoices and expense receipts (Section 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO, Section 14b(1) UStG and Section 257(1) no. 4 in conjunction with (4) HGB).
• 6 years – other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are of relevance for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labelling, but also payroll documents insofar as they are not already accounting vouchers, and till rolls (Section 147(1) nos. 2, 3, 5 in conjunction with (3) AO, Section 257(1) nos. 2 and 3 in conjunction with (4) HGB).
• 3 years – data required to consider potential warranty and compensation claims or similar contractual claims and rights, and to process related enquiries, based on past business experience and customary industry practice, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the point in time at which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

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

• Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent given at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain access to that data as well as further information and a copy of the data in accordance with the statutory requirements.
• Right to rectification: In accordance with the statutory requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with the statutory requirements, to request a restriction of the processing of the data.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with the statutory requirements, or to request its transmission to another controller.
• Right to lodge a complaint with a supervisory authority: In accordance with the statutory requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority 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.

Reach measurement (Vercel Web Analytics)

We measure the reach of our online offering using Vercel Web Analytics, a service provided by Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA.

The data recorded comprises the pages accessed, the referring source, the approximate region of origin at country level, and device type, operating system and browser. Evaluation is carried out exclusively in aggregate form.

The service operates without cookies and does not store or read any information on your device. No user profiles are created, no returning visitors are recognised and no data is combined across different websites. Identification of individual persons is neither intended nor possible. We do not use A/B testing or comparable testing procedures.

As no access to your device takes place, consent under Section 25 TDDDG (German Telecommunications Digital Services Data Protection Act) is not required. The legal basis is our legitimate interest in the statistical evaluation of usage and the improvement of our offering pursuant to Art. 6(1)(f) GDPR.

Purpose: reach measurement. Types of data processed: usage data as well as meta and communication data. Data subjects: users. Retention: no individual personal records are kept; the evaluations are aggregated.

Transfer to the USA takes place on the basis of standard contractual clauses. Data processing agreement: vercel.com/legal/dpa — provider's privacy policy: vercel.com/legal/privacy-policy

Embedded videos (YouTube)

On our „Speaking“ page, a video hosted on YouTube is embedded. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The video is only loaded once you expressly start playback by clicking. Before this click, no data is transmitted to YouTube and no connection to Google is established.

We use the extended data protection mode (youtube-nocookie.com). In this mode, according to YouTube's own statements, no cookies are set for advertising purposes as long as no video is played. When playback starts, your IP address and information about your device and browser are transmitted to Google; if you are logged in to Google, the usage may be associated with your account.

The legal basis is our legitimate interest in an appealing presentation of our offering pursuant to Art. 6(1)(f) GDPR.

Provider's privacy policy: business.safety.google/privacy

Language preference in browser storage

This website remembers your language selection in an entry in your browser's local storage (localStorage) under the name kh-lang. The entry is set exclusively by your own use of the language switch, contains no personal data, is not transmitted and does not enable recognition.

It is therefore strictly necessary for the service expressly requested by you within the meaning of Section 25(2) no. 2 TDDDG; consent is not required. You can delete it at any time via your browser settings. We do not use any other cookies or comparable storage technologies.

Business services

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

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

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

In addition, we process the data to safeguard our rights and to comply with legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations and, where applicable, obligations of proof and accountability. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners against misuse, endangerment of data, trade secrets and other legally protected interests. This may also involve engaging external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other vicarious agents, insofar as this is necessary for the performance of the contract or to comply with legal obligations.

Personal data is only passed on to third parties where this is necessary for the performance of the contract, for pre-contractual measures, to safeguard legitimate interests or to comply with legal obligations. We provide separate information within this privacy policy about any processing that goes beyond this, in particular for marketing purposes.

We inform contractual partners which data is required in an individual case at the time of collection, for example through corresponding labelling in online forms or in personal contact.

Data is erased as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations conflict with erasure. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific assignment is erased by us after completion of the assignment and expiry of any retention periods, provided that no further statutory or contractual storage obligations exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and performing the respective contractual relationship, and Art. 6(1)(c) GDPR for compliance with legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves our legitimate interests in proper and efficient business organisation, the internal administration and documentation of business transactions, the assertion and defence of legal claims, ensuring IT and data security, preventing misuse and fraud, and the commercial management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in preserving our entrepreneurial capacity to act.

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

Further information on processing operations, procedures and services:

• Consulting: We process the data of our clients as well as prospective clients and other principals or contractual partners (uniformly referred to as „clients“) in order to be able to provide our services to them. The procedures forming part of, and serving the purposes of, consulting include: making contact and communicating with clients, carrying out needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, recording and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, billing and payment management, follow-up of consulting projects, quality assurance and feedback processes. The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
  
  Insofar as this is necessary for the performance of our contract, to protect vital interests or is required by law, or where the client has given consent, we disclose or transmit client data — in compliance with professional requirements — to third parties or agents, such as public authorities, subcontractors or providers in the field of IT, office or comparable services; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR).

Business processes and procedures

Personal data of recipients of services and principals — including customers, clients or, in specific cases, mandators, patients or business partners as well as further third parties — is processed in the context of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates commercial procedures in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected serves to fulfil contractual obligations and to design operational processes efficiently. This includes the handling of business transactions, the management of customer relationships, the optimisation of sales strategies and the assurance of internal invoicing and financial processes. In addition, the data supports the safeguarding of the controller's rights and promotes administrative tasks and the organisation of the business.

Personal data may be passed on to third parties insofar as this is necessary to fulfil the stated purposes or legal obligations. Once statutory retention periods have expired or the purpose of processing ceases to apply, the data is erased. This also includes data that must be stored for longer due to tax law and statutory evidence obligations.

• Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files concerning logins or the retrieval of data or access times); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
• Data subjects: Recipients of services and clients; prospective clients; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services). Clients.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and commercial procedures; communication; marketing; sales promotion; public relations; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Retention and erasure: Erasure in accordance with the information in the section „General information on data storage and erasure“.
• Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR). Legal obligation (Art. 6(1)(1)(c) GDPR).

Further information on processing operations, procedures and services:

• Client management: Procedures required in the context of client management include, for example, the acquisition and onboarding of new clients, the development of strategies to promote client retention, and ensuring effective client communication and appointment scheduling. Comprehensive client service is provided. These procedures also include maintaining and managing client files, the secure documentation of legal matters, and ensuring the confidentiality and integrity of client data. Processes are also defined for passing on client information to third parties, such as courts or other legal service providers. Procedures are implemented for the secure and data protection compliant erasure of client data as soon as it is no longer required or statutory retention periods have expired; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• Contact management and contact maintenance: Procedures required in the context of organising, maintaining and securing contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training staff in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• General payment transactions: Procedures required when carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, handling direct debits, checking account statements, monitoring incoming and outgoing payments, direct debit return management, account reconciliation, cash management); Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• Accounting, accounts payable, accounts receivable: Procedures required when recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. creating and checking incoming and outgoing invoices, monitoring and managing open items, carrying out payment transactions, handling dunning procedures, account reconciliation in the context of receivables and liabilities, accounts payable and accounts receivable accounting); Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• Financial accounting and taxes: Procedures required when recording, managing and controlling financially relevant business transactions as well as calculating, reporting and paying taxes (e.g. account assignment and posting of business transactions, preparing quarterly and annual financial statements, carrying out payment transactions, handling dunning procedures, account reconciliation, tax advice, preparing and filing tax returns, handling tax matters); Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legal obligation (Art. 6(1)(1)(c) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• Sales: Procedures required when planning, carrying out and controlling measures for marketing and selling products or services (e.g. customer acquisition, preparing and following up quotations, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
• Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group definition, development of marketing strategies, planning and carrying out advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
• Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and carrying out PR campaigns, preparing and distributing press releases, maintaining media contacts, monitoring and analysing media response, organising press conferences and public events, crisis communication, producing content for social media and corporate websites, managing corporate branding); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Provision of the online offering and web hosting

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

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

Further information on processing operations, procedures and services:

• Provision of the online offering on rented storage space: For the provision of our online offering we use storage space, computing capacity and software which we rent or otherwise obtain from a corresponding server provider (also referred to as a „web host“); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called „server log files“. Server log files may include the address and name of the web pages and files accessed, the date and time of access, volumes of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is required for evidentiary purposes is exempt from erasure until the respective incident has been finally clarified.
• bunny.net: Content delivery network (CDN) – a service that enables content of an online offering, in particular large media files such as graphics or program scripts, to be delivered more quickly and securely with the help of regionally distributed servers connected via the internet. We use the service exclusively to deliver the fonts used on this website (Bunny Fonts); Service provider: BUNNYWAY d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: bunny.net; Privacy policy: bunny.net/privacy. Data processing agreement: Provided by the service provider.
• Vercel: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity) as well as a development environment; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: vercel.com; Privacy policy: vercel.com/legal/privacy-policy; Data processing agreement: vercel.com/legal/dpa. Basis for third-country transfers: Standard contractual clauses.

Contact and enquiry management

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

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

Further information on processing operations, procedures and services:

• Contact form: When you contact us via our contact form, by email or by other means of communication, we process the personal data transmitted to us in order to answer and handle the respective request. This generally includes details such as name, contact information and, where applicable, further information communicated to us and required for appropriate handling. We use this data exclusively for the stated purpose of making contact and communicating. The message sent via the form is delivered to us by email and is not stored in a database in the process; delivery is handled by the service provider Brevo (Sendinblue GmbH, Berlin) named under „Newsletter and electronic notifications“; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Artificial intelligence (AI)

We use artificial intelligence (AI), in the course of which personal data is processed. The specific purposes and our interest in using AI are set out below. By AI we mean, in accordance with the concept of an „AI system“ under Article 3(1) of the AI Act, a machine-based system designed to operate with varying levels of autonomy, that may exhibit adaptiveness after deployment and that infers, from the input it receives, how to generate outputs such as predictions, content, recommendations or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with the statutory requirements. These comprise both specific rules for artificial intelligence and data protection requirements. In doing so, we observe in particular the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation and integrity and confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This may be either the consent of the data subjects or a statutory permission.

When using external AI systems, we select their providers (hereinafter „AI providers“) carefully. In accordance with our statutory obligations, we ensure that the AI providers comply with the applicable provisions. We likewise observe the obligations incumbent upon us when using or operating the AI services obtained. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or statutory authorisation. We attach particular importance to transparency, fairness and the preservation of human oversight of AI-supported decision-making processes.

To protect the data processed, we implement appropriate and robust technical and organisational measures. These ensure the integrity and confidentiality of the data processed and minimise potential risks. Through regular reviews of the AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

• Types of data processed: Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services). Third parties.
• Purposes of processing and legitimate interests: Artificial intelligence (AI).
• Retention and erasure: Erasure in accordance with the information in the section „General information on data storage and erasure“.
• Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Claude API: AI-supported service designed to understand and generate natural language and related inputs, to analyse information and to make predictions („AI“, i.e. „artificial intelligence“, is to be understood in the respectively applicable legal sense of the term). The provision of the AI services includes the processing (including collection, storage, organisation and structuring) of personal data within a natural language based machine learning procedure; the carrying out of measures to review and maintain the quality of the services; the identification and remedying of errors that may impair the intended functionality; and support in ensuring the security and integrity of the AI services; Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: anthropic.com; Privacy policy: anthropic.com/legal/privacy; Data processing agreement: anthropic.com/legal/data-processing-addendum. Basis for third-country transfers: Standard contractual clauses.

Cloud services

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

In this context, personal data may be processed and stored on the providers' servers, insofar as such data forms part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and service optimisation.

Insofar as we use cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users' devices for the purposes of web analysis or in order to remember user settings (e.g. in the case of media controls).

• Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Prospective clients; communication partners. Business and contractual partners.
• Purposes of processing and legitimate interests: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
• Retention and erasure: Erasure in accordance with the information in the section „General information on data storage and erasure“.
• Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Apple iCloud: Cloud storage service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: apple.com. Privacy policy: apple.com/legal/privacy.
• Microsoft 365 and Microsoft cloud services: Provision of applications, protection of data and IT systems, and use of system-generated log, diagnostic and metadata for the performance of the contract by Microsoft. The data processed comprises contact data (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe) as well as log and metadata. Processing takes place for the purposes of efficiency and productivity gains, cost efficiency, flexibility, mobility, improved communication, integration of Microsoft services, IT security and Microsoft's business operations. Data retention is governed by the respective documents and company policies; for Defender (protection of data and IT systems) up to 12 months, for print management 10 days. In addition, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: microsoft.com; Privacy policy: privacy.microsoft.com; Data processing agreement: Microsoft Products and Services DPA. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses.

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter „newsletter“) exclusively with the consent of the recipients or on a statutory basis. Where the contents of a newsletter are described during sign-up, those contents are decisive for the users' consent. To sign up for our newsletter it is normally sufficient to provide your email address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that you can be addressed personally in the newsletter, or for further information if this is necessary for the purpose of the newsletter.

Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before erasing them, in order to be able to demonstrate consent previously given. The processing of this data is restricted to the purpose of potentially defending against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The sign-up procedure is logged on the basis of our legitimate interests for the purpose of demonstrating that it was carried out properly. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents: Information about us, our services, campaigns and offers.

• Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors).
• Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).
• Right to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you may otherwise use one of the contact options given above, preferably email.

Further information on processing operations, procedures and services:

• Brevo: Email delivery and automation services. We use Brevo to deliver the messages sent via our enquiry form; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: brevo.com; Privacy policy: brevo.com/legal/privacypolicy. Data processing agreement: Provided by the service provider.
• beehiiv: Delivery of our newsletter. On sign-up we collect only your email address; no further details are required. The sign-up is forwarded to beehiiv via a server under our control.
  
  After signing up you will receive an email asking you to confirm. Only after this confirmation do we add you to the distribution list (double opt-in procedure). Sign-up, confirmation and sending times are logged in order to be able to demonstrate consent.
  
  By default, beehiiv records whether and when you open a newsletter email and whether you click on links contained in it. This performance measurement serves to evaluate which content is of interest.
  
  The legal basis is your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 7(2) no. 3 of the German Act Against Unfair Competition (UWG). You may withdraw your consent at any time with effect for the future, for example via the unsubscribe link at the end of each newsletter email. We store unsubscribed addresses for up to three years in order to be able to demonstrate consent previously given; processing is restricted to this purpose.
  
  Types of data processed: contact data as well as meta, communication and usage data. Data subjects: communication partners.
  
  Third-country transfer: standard contractual clauses. Data processing agreement: provided by the service provider; Service provider: beehiiv Inc., 228 Park Avenue, New York, NY 10003, USA; Website: beehiiv.com. Privacy policy: beehiiv.com/privacy.

Presence on social networks (social media)

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

We point out that user data may be processed outside the European Union in this context. This may give rise to risks for users, because, for example, the enforcement of users' rights could be made more difficult.

Furthermore, users' data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created on the basis of usage behaviour and the resulting interests of users. These profiles may in turn be used to place advertisements inside and outside the networks that are presumed to correspond to users' interests. For this reason, cookies are generally stored on users' computers, in which usage behaviour and users' interests are stored. Moreover, data may also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and logged in there).

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

In the case of requests for access and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the latter have access to users' data in each case and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you may contact us.

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

Further information on processing operations, procedures and services:

• LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create the „Page Insights“ (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles such as job function, country, industry, seniority, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy notice: linkedin.com/legal/privacy-policy.
  
  We have concluded a special agreement with LinkedIn Ireland („Page Insights Joint Controller Addendum“, legal.linkedin.com/pages-joint-controller-addendum), which governs in particular the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users may, for example, address requests for access or erasure directly to LinkedIn). Users' rights (in particular the right of access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transfer of the data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular as regards the transfer of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: linkedin.com; Privacy policy: linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses. Right to object (opt-out): LinkedIn retargeting opt-out.

Management, organisation and support tools

We use services, platforms and software of other providers (hereinafter referred to as „third-party providers“) for the purposes of organisation, administration, planning and the provision of our services. When selecting third-party providers and their services, we observe the statutory requirements.

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

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

• Types of data processed: Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); master data (e.g. full name, residential address, contact information, customer number, etc.). Contact data (e.g. postal and email addresses or telephone numbers).
• Data subjects: Communication partners; users (e.g. website visitors, users of online services); prospective clients. Business and contractual partners.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; communication. Organisational and administrative procedures.
• Retention and erasure: Erasure in accordance with the information in the section „General information on data storage and erasure“.
• Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

• Cal.com: Appointment scheduling platform that enables online bookings, calendar integrations and automated reminders, and offers functions such as team scheduling and video conferencing integrations, while processing personal data in order to organise and manage appointments. On our website, the booking dialogue is only loaded once you expressly open it by clicking a corresponding button; before this click, no data is transmitted to Cal.com; Service provider: Cal.com, Inc., 2261 Market Street #4368, 94114 San Francisco, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: cal.com; Privacy policy: cal.com/privacy; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Standard contractual clauses (provided by the service provider).

Amendment and updating

We ask you to inform yourself regularly 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 an act of cooperation on your part (e.g. consent) or other individual notification.

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

Competent supervisory authority

The supervisory authority responsible for us:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
(State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia)
Postfach 20 04 44
40102 Düsseldorf, Germany
Telephone: +49 211 38424-0
Email: poststelle@ldi.nrw.de

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, the statutory definitions apply. The following explanations are intended primarily to aid understanding.

• Master data: Master data comprises essential information required for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions or systems, by enabling unambiguous assignment and communication.
• Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata providing information about the content itself, such as tags, descriptions, author information and publication dates.
• Contact data: Contact data is essential information that enables communication with persons or organisations. It includes telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Artificial intelligence (AI): The purpose of processing data by means of artificial intelligence (AI) comprises the automated analysis and processing of user data in order to recognise patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of the data, the training and application of AI models, and the continuous review and optimisation of the results, and takes place exclusively with the consent of users or on the basis of statutory grounds for permission.
• Meta, communication and procedural data: Meta, communication and procedural data are categories containing information about the manner in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information describing the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a broad range of information showing how users use applications, which functions they prefer, how long they spend on particular pages and which paths they take when navigating an application. Usage data may also include the frequency of use, time stamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Usage data also plays a decisive role in identifying trends, preferences and possible problem areas within digital offerings.
• Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Log data: Log data is information about events or activities that have been recorded in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to produce performance reports.
• Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may cover the behaviour or interests of visitors in particular information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, identify at what times users visit their web pages and which content they are interested in. This enables them, for example, to better adapt the content of the web pages to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
• Controller: „Controller“ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: „Processing“ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether collection, evaluation, storage, transmission or erasure.
• Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This data category is essential for the administration and fulfilment of contractual obligations and covers both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, pricing arrangements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is decisive for clarifying rights and obligations, enforcing claims and resolving disputes.
• Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of decisive importance for electronic commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also contain information about payment status, chargebacks, authorisations and fees.

Legal text created with the privacy policy generator by Dr. Schwenke. English translation provided for convenience; the German version prevails.