Privacy Policy

1. Introduction

With the following information we would like to give you as a “data subject” an overview of the collection, use and processing of your personal data by us and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent.

The processing of personal data, such as your name, address, or e-mail address, shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the data protection provisions applicable to us. As the responsible entity, we have implemented numerous technical and organizational measures to ensure the protection of personal data processed through this website. Nevertheless, Internet-based data transmissions may be subject to security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by mail.

2. Responsible Entity

Responsible entity in accordance to GDPR is:

Represented by Managing Directors: Philipp Hartmann, Patrick Metzler, Steven Mewissen, Jörg Poplawsky, Marc Schnitzler

3. Data Protection Officer

You can reach the data protection officer as follows:

You can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.

4. Legal Basis of Processing

Article 6 (1) lit. a GDPR (in conjunction with Section 25 (1) TTDSG) serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the fulfillment of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Article 6 (1) lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR.

Ultimately, processing operations could be based on Art. 6 (1) lit. f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not outweigh the aforementioned bases. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 GDPR).

5. Transmission of Data to Third Parties

We do not transfer your personal data to third parties for purposes other than those listed below. We only pass on your personal data to third parties if:

• You have given us your express consent to do so in accordance with Art. 6 Para. 1 lit. a GDPR,
• The disclosure is permissible under Art. 6 (1) (f) GDPR to protect our legitimate interests and there is no reason to assume that you have an outweighing interest worthy of protection in the non-disclosure of your data,
• In the event that a legal obligation exists for the disclosure pursuant to Art. 6 (1) c GDPR, and
• This is legally permissible and necessary for the processing of contractual relationships with you according to Art. 6 para. 1 lit. b GDPR.

Within the scope of the processing operations described in this privacy policy, personal data may be transferred to the USA. The USA does not have an adequate level of data protection (ECJ: Schrems II ruling). In particular, U.S. investigative authorities can oblige U.S. companies to hand over or disclose personal data without the data subjects being able to effectively take legal action against this. Thus, in principle, there is a possibility that your personal data will be processed by U.S. investigative authorities. We have no influence on these processing activities. In order to protect your data, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent can serve as a legal basis for the transfer to third countries in accordance with Art. 49 (1) a) GDPR. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 GDPR.

6. Technical Data & Server Log Files

When you use our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called “server log files”). Our website collects a series of general data and information with each call of a page by you or an automated system. This general data and information is stored in the server log files. The following data may be collected:

• The browser types and versions used,
• The operating system used by the accessing system,
• The website from which an accessing system arrives at our website (so-called referrer),
• The sub-websites that are accessed via an accessing system on our website,
• The date and time of an access to the Internet site,
• The Internet protocol address (IP address), and
• The Internet service provider of the accessing system.

When using this general data and information, we do not draw any conclusions about your person. Rather, this information is needed to deliver the content of our website correctly, to optimize the content of our website as well as the advertising for it, to ensure the long-term functionality of our IT systems and the technology of our website as well as to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

Therefore, the data and information collected is, on the one hand, statistically analyzed by us and, on the other hand, it is evaluated with the aim of increasing the data protection and data security of our enterprise to ultimately ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from any personal data provided by a data subject and are automatically deleted after 7 days. The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f GDPR. Our legitimate interest follows from the purposes for data collection listed above.

7. Cookies

We use cookies on our website. These are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site. Cookies do not cause any damage to your end device, do not contain viruses, trojans or other malware. In the cookie, information is stored that arises in each case in connection with the specific end device used. This does not mean, however, that we gain direct knowledge of your identity. The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site. On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These cookies enable us to automatically recognize that you have already been to our site when you visit it again. These cookies are automatically deleted after a defined period of time. The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests as well as the legitimate interests of third parties pursuant to Art. 6 (1) p. 1 lit. f GDPR.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a notice always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website.

8. Consent Management

We use a consent banner on our website to obtain and manage your consent for data processing that is not strictly necessary for the operation of the site (in particular analytics). When you make a selection in the banner, your choice is stored locally in your browser so that the website can read and follow your decision on subsequent visits. No tracking or analytics cookies are set until you have given your explicit consent. You can withdraw your consent at any time with effect for the future by clearing the consent setting in your browser. The legal basis for obtaining consent is Art. 6 (1) lit. a GDPR in conjunction with Section 25 (1) TTDSG.

9. Google Analytics

On our websites, we use Google Analytics, a web analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). The service uses “cookies”, which are stored on your accessing device. The information collected by the cookies is usually transmitted to a Google server in the USA and stored there. IP anonymization is used on this website. The IP address of the user is shortened within the member states of the EU and the European Economic Area. This shortening eliminates the personal reference of your IP address. Under the terms of the commissioned data agreement that we have concluded with Google, the latter uses the information collected to create an evaluation of website use and website activity and provides services associated with internet use. These processing operations are carried out exclusively with the granting of explicit consent in accordance with Art. 6 (1) lit. a GDPR.

You have the option to prevent the storage of the cookie on your device by making the appropriate settings in your browser; however, we would like to point out that in this case not all functions of this website may be used to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on. You may also opt to use an opt-out cookie that prevents the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

10. Google Search Console

For the purpose of continuously optimizing the Google ranking of our website, we use Google Search Console, a web analytics service provided by Google. Through Google Search Console, we can perform search analytics that tell us how often our website appears in Google search results. This allows us to monitor and manage our website in the search index. No personal user or tracking data is processed or transmitted to Google as part of the use of Google Search Console.

11. Contents of Our Website

Contacting / contact form: When contacting us (e.g. via contact form or e-mail), personal data is collected to the extent necessary. Which data is specifically collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request and the associated technical administration.

The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f GDPR. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1 lit. b GDPR. Your data will be deleted after final processing of your request; this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and provided that there are no statutory retention obligations.