Privacy Policy & Legal Notice

Privacy Policy

This Privacy Policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the associated websites, features, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “Online Offering”). With regard to the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Types of data processed:

– Master data (e.g., names, addresses).
– Contact data (e.g., email, phone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects

Visitors and users of the online service (hereinafter, we collectively refer to these individuals as “users”).
Purpose of processing

– Providing the online service, its features, and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Audience measurement/marketing

Terminology Used

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

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

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

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

The term “controller” refers to the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor”: a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
Applicable Legal Bases

In accordance with Article 13 of the GDPR, we are providing you with the legal bases for our data processing activities. Unless the legal basis is specified in the Privacy Policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 of the GDPR; the legal basis for processing to fulfill our services, carry out contractual obligations, and respond to inquiries is Article 6(1)(b) of the GDPR; the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) of the GDPR, and the legal basis for processing to protect our legitimate interests is Article 6(1)(f) of the GDPR. In cases where the vital interests of the data subject or another natural person necessitate the processing of personal data, Article 6(1)(d) of the GDPR serves as the legal basis.

Safety Measures

In accordance with Article 32 of the GDPR, and taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access to, input of, and disclosure of the data, ensuring its availability, and maintaining data segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and a response to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).
Cooperation with Data Processors and Third Parties

If, in the course of our data processing, we disclose data to other individuals or companies (processors or third parties), transfer it to them, or otherwise grant them access to the data, this is done only on the basis of legal authorization (e.g., if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Article 6(1)(b) of the GDPR), you have given your consent, a legal obligation requires it, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).

If we engage third parties to process data on the basis of a so-called “data processing agreement,” this is done in accordance with Article 28 of the GDPR.

Transfers to Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in connection with the use of third-party services or the disclosure or transfer of data to third parties, we do so only if it is necessary to fulfill our (pre)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to statutory or contractual permissions, we process data in a third country or have it processed there only if the specific requirements of Articles 44 et seq. of the GDPR are met. This means that processing takes place, for example, on the basis of specific safeguards, such as an officially recognized determination that a country provides a level of data protection equivalent to that of the EU (e.g., for the U.S. through the “Privacy Shield”) or compliance with officially recognized specific contractual obligations (so-called “Standard Contractual Clauses”).

Rights of Data Subjects

You have the right to request confirmation as to whether the relevant data is being processed, as well as access to that data, further information, and a copy of the data in accordance with Article 15 of the GDPR.

Pursuant to Article 16 of the GDPR, you have the right to request that the data concerning you be completed or that any inaccurate data concerning you be corrected.

Pursuant to Article 17 of the GDPR, you have the right to request that the relevant data be erased without delay; alternatively, pursuant to Article 18 of the GDPR, you have the right to request a restriction on the processing of the data.

You have the right to request that we provide you with the personal data concerning you that you have provided to us, in accordance with Article 20 of the GDPR, and to request that we transfer that data to other data controllers.

Furthermore, pursuant to Article 77 of the GDPR, you have the right to file a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to withdraw any consent you have given in accordance with Article 7(3) of the GDPR, effective for the future.

Right to Object

You may object at any time to the future processing of your personal data in accordance with Article 21 of the GDPR. In particular, you may object to processing for direct marketing purposes.

Cookies and the Right to Object to Direct Marketing

“Cookies” are small files that are stored on users’ computers. Various types of information can be stored in cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or even after the user’s visit to a website. “Temporary cookies,” also known as “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can, for example, store the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent.” For example, a user’s login status may be stored so that it remains active when the user returns to the site several days later. Similarly, such cookies may store users’ interests, which are used for audience measurement or marketing purposes. “Third-party cookies” are cookies provided by parties other than the controller operating the online service (in contrast, when only the controller’s own cookies are used, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies, and we provide information about this in our Privacy Policy.

If users do not want cookies to be stored on their computers, they are asked to disable the corresponding option in their browser's settings. Stored cookies can be deleted in the browser's settings. Disabling cookies may result in limited functionality of this website.

A general objection to the use of cookies for online marketing purposes can be submitted for a wide range of services—particularly in the case of tracking—via the U.S. website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, you can prevent cookies from being stored by disabling them in your browser settings. Please note that doing so may prevent you from using all features of this website.

Deletion of Data

The data we process will be erased or its processing restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated otherwise in this Privacy Policy, the data we store will be erased as soon as it is no longer necessary for the purpose for which it was collected and there are no legal retention obligations preventing its erasure. If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted. This means that the data will be blocked and will not be processed for any other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

In accordance with German legal requirements, records must be retained for a period of 10 years, in particular pursuant to Sections 147(1) of the German Fiscal Code (AO), §§ 257(1) nos. 1 and 4, (4) of the German Commercial Code (HGB) (books, records, management reports, accounting documents, trading ledgers, documents relevant for tax purposes, etc.) and for 6 years pursuant to § 257(1) nos. 2 and 3, (4) of the German Commercial Code (HGB) (business correspondence).

In accordance with Austrian law, records must be retained for 7 years pursuant to § 132(1) of the Austrian Federal Tax Code (BAO) (accounting records, receipts/invoices, accounts, supporting documents, business records, statements of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents related to electronically supplied services, telecommunications, radio, and television services provided to non-business customers in EU member states for which the Mini One-Stop Shop (MOSS) is used.

Newsletter

The following information explains the content of our newsletter, as well as the procedures for subscription, distribution, and statistical analysis, and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described herein.

Newsletter Content: We send newsletters, emails, and other electronic notifications containing promotional information (hereinafter “newsletters”) only with the recipients’ consent or when permitted by law. If the newsletter’s content is specifically described during the sign-up process, that description serves as the basis for the users’ consent. In addition, our newsletters contain information about our services and our company.

Double Opt-In and Logging: Signing up for our newsletter is done through a so-called double opt-in process. This means that after signing up, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that no one can sign up using someone else’s email address. Newsletter subscriptions are logged so that we can verify the subscription process in accordance with legal requirements. This includes storing the time of subscription and confirmation, as well as the IP address. Changes to your data stored with the email service provider are also logged.

Subscription Information: To subscribe to the newsletter, simply provide your email address. Optionally, we ask that you provide a name so we can address you personally in the newsletter.

The distribution of the newsletter and the associated performance measurement are based on the recipients’ consent pursuant to Art. 6(1)(a), Article 7 of the GDPR in conjunction with Section 7(2)(3) of the UWG; or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Article 6(1)(f) of the GDPR in conjunction with Section 7(3) of the UWG.

The registration process is logged based on our legitimate interests pursuant to Article 6(1)(f) of the GDPR. Our interest is focused on using a user-friendly and secure newsletter system that serves both our business interests and meets user expectations, and that also allows us to provide proof of consent.

Unsubscribe/Withdrawal – You can unsubscribe from our newsletter at any time, i.e., withdraw your consent. A link to unsubscribe from the newsletter can be found at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the prior existence of consent is confirmed at the same time.

Newsletter – Mailchimp

Newsletters are sent via the mailing service provider “MailChimp,” a newsletter distribution platform operated by the U.S. company Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the mailing service provider’s privacy policy here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC, doing business as MailChimp, is certified under the Privacy Shield Framework and thereby guarantees compliance with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The mailing service provider is engaged on the basis of our legitimate interests pursuant to Art. 6(1)(f) of the GDPR and a data processing agreement pursuant to Art. 28(3), sentence 1 of the GDPR.

The email service provider may use the recipients’ data in pseudonymous form—that is, without linking it to a specific user—to optimize or improve its own services, such as for technical optimization of email delivery and newsletter layout, or for statistical purposes. However, the email service provider does not use the data of our newsletter recipients to contact them directly or to share the data with third parties.

Newsletter – Measuring Success

The newsletters contain a so-called “web beacon,” which is a pixel-sized file that is retrieved from our server—or, if we use a mailing service provider, from that provider’s server—when you open the newsletter. When this file is retrieved, technical information—such as details about your browser and system, as well as your IP address and the time of retrieval—is collected.

This information is used to improve our services technically based on technical data, or to analyze target audiences and their reading behavior based on their location (which can be determined using their IP address) or access times. Statistical analyses also include determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be traced back to individual newsletter recipients. However, it is neither our intention nor—if a mailing service provider is used—the provider’s intention to monitor individual users. Rather, the analyses help us identify our users’ reading habits and tailor our content accordingly, or send different content based on our users’ interests.

Unfortunately, it is not possible to cancel the performance tracking feature separately; in this case, the entire newsletter subscription must be canceled.

Hosting and Email Delivery

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

In this context, we—or our hosting provider—process master data, contact data, content data, contract data, usage data, metadata, and communication data from customers, prospective customers, and visitors to this online service based on our legitimate interests in providing this online service efficiently and securely, in accordance with Article 6(1)(f) of the GDPR in conjunction with Article 28 of the GDPR (conclusion of a data processing agreement).

Collection of Access Data and Log Files

We, or rather our hosting provider, collect data regarding every access to the server on which this service is located (so-called server log files) based on our legitimate interests within the meaning of Article 6(1)(f) of the GDPR. The access data includes the name of the webpage accessed, the file, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), the IP address, and the requesting provider.

For security reasons (e.g., to investigate cases of misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.