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Disclaimer: The following template was created by an attorney (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV), Certified Data Protection Officer (TÜV Süd)) in accordance with the typical requirements of an online store. However, you should only use the template after careful review and adaptation to your specific business model. The following template therefore contains additional information that you must observe and red passages that you must particularly check and, if necessary, adapt. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the template within the domain/website as long as your Marketpress license is valid for it. Disclosure to third parties, including customers (e.g., as a developer), is not permitted.

Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also briefly referred to as “data”) that 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, mobile, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).

The terms used are not gender-specific.

As of: XX.XX.20XX

Please state the effective date of the privacy policy.

Table of Contents

Controller

First Name, Last Name / Company
Street, House No.
Zip Code, City
Country

Email Address: Your email address

Phone: Your phone number (optional)

Imprint: URL of your imprint (optional, but recommended)

Notes: For sole proprietors, please use the term “Owner” and not “Managing Director.”

Contact Data Protection Officer

First Name, Last Name / Company
Street, House No.
Zip Code, City
Country

Note: Only the email address is mandatory; the other details are optional. Data protection officers only need to be specified if they have been appointed. An appointment is necessary according to Section 38 BDSG-Neu (Federal Data Protection Act-New) for 20 or more employees who process personal data (for which an email inbox is practically sufficient).

Overview of Processing Activities

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

Note: The following information includes typical processed data and categories of data subjects (these themselves, as well as the explanations in parentheses, are for clarification only and can be adapted or deleted).

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Automated Individual Decision-Making

Applicable Legal Bases

Below, we communicate the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the GDPR regulations, national data protection requirements in your or our country of residence and establishment may apply. Furthermore, if more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.

Security Measures

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

Measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

SSL encryption (https): To protect your data transmitted via our online services, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Note: Remove the reference to encryption if your service is not encrypted. However, delivering the website via https should be considered mandatory.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it may happen that data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if processing takes place in the context of using third-party services or disclosing/transmitting data to other persons, entities, or companies, this is only done in compliance with legal requirements.

Subject to explicit consent or contractually or legally required transmission, we process or have data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard contractual clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Within the framework of the “Data Privacy Framework” (DPF), the EU Commission has also recognized the data protection level as secure for certain companies from the USA within the scope of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you within the privacy notices which of our service providers are certified under the Data Privacy Framework.

Use of Cookies

Cookies are small text files, or other storage notes, that store information on end devices and read information from end devices. For example, to store the login status in a user account, shopping cart content in an e-shop, the content accessed, or functions used in an online offering. Cookies can also be used for different purposes, e.g., for the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal provisions. Therefore, we obtain prior consent from users, unless this is not legally required. Consent is particularly not necessary if the storage and reading of information, including cookies, are absolutely essential to provide users with a telemedia service (i.e., our online services) explicitly requested by them. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the economic operation of our online services and improving its usability) or, if this occurs within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will clarify the purposes for which we process cookies in the course of this privacy policy or within our consent and processing procedures.

Storage duration: With regard to storage duration, the following types of cookies are distinguished:

General notes on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection via your browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you may receive further objection information within the details of the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management procedure, within which users’ consents to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained, managed, and revoked by users. The declaration of consent is stored to avoid having to repeat its query and to be able to prove the consent in accordance with legal obligations. Storage can take place server-side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following notes apply: The duration of consent storage can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.

Cookie Settings / Opt-Out Option:

If you use a cookie consent banner (which is recommended), you can enter the option to call it up here (e.g., a link or a so-called [shortcode] that is automatically converted into a button/link by your software).

Notes on the processing of cookie data based on consent: You should only keep this option (and otherwise delete it) if you obtain a “real” opt-in, i.e., consent from users for the use of cookies (e.g., with so-called “cookie consent/opt-in banners” or as part of a registration process).

Since a cookie opt-in is generally necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g., Google Analytics or Facebook Pixel), this option is pre-selected.

This means that you do not use any cookies (and do not use any third-party services within your websites that themselves use cookies) until users have given their consent. Only the use of necessary cookies that are expected by users, such as a shopping cart function in the online shop or local reach measurement with the Matomo tool, is permissible.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively “contractual partners”), for the initiation, execution, 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 fulfill our primary and secondary contractual obligations. This includes the provision of agreed services, any updating and information obligations, the processing of warranty and other service disruptions, the handling of revocations, terminations of long-term obligations, reversals, refunds, and the processing of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.

In particular, master data such as name, address, and possibly company, contact data such as email address and telephone number, contract and service data such as the 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 are processed. To the extent necessary, we also process data disclosed or transmitted to us in the course of executing an order.

Furthermore, we process the data to safeguard our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation obligations, and, if applicable, proof and accountability obligations. In addition, processing is carried out 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 from misuse, data breaches, disclosure of secrets, and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other vicarious agents, insofar as this is necessary for contract execution or to fulfill legal obligations.

Personal data is only passed on to third parties insofar as this is necessary for the performance of the contract, for the implementation of pre-contractual measures, for safeguarding legitimate interests, or for fulfilling legal obligations. We will inform you separately about further processing, especially for marketing purposes, within this privacy policy.

We will inform contractual partners about which data is required in individual cases during data collection, for example, in online forms through appropriate labeling or in personal contact.

Data will be deleted as soon as it is no longer required for the aforementioned purposes and no legal retention obligations prevent deletion. Legal retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order will be deleted by us after completion of the order and expiry of any retention periods, unless there are further legal or contractual obligations to store it.

The legal basis for processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Insofar as processing is based on Art. 6 para. 1 lit. f GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests exist in particular in ensuring secure and legally compliant business operations and in safeguarding our entrepreneurial capacity to act.

Customer account: Contractual partners can create an account within our online services (e.g., customer or user account, briefly “customer account”). If the registration of a customer account is required, contractual partners will be informed of this, as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration, as well as subsequent logins and uses of the customer account, we store the IP addresses of customers along with the access times to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data related to the customer account will be deleted, subject to legal retention requirements.

Economic analyses and market research: For business reasons and to identify market trends, wishes of contractual partners and users, we analyze the data available to us regarding business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, prospective customers, customers, visitors, and users of our online services.

The analyses are carried out for the purpose of business evaluations, marketing, and market research (e.g., to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users including their details, e.g., on services used. The analyses are for our sole benefit and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized values. Furthermore, we respect the privacy of users and process data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Shop and E-commerce: We process the data of our customers to enable them to select, purchase, or order the chosen products, goods, and associated services, as well as their payment and provision, delivery, or execution. If necessary for the execution of an order, we use service providers, in particular postal, freight, and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such within the order or comparable purchase process and includes the information necessary for delivery or provision and billing, as well as contact information to allow for any queries.

Note: Please remove the passage on customer accounts or customer data analysis if you do not offer a customer account or do not analyze your customer data as described.

Payment Service Providers

Within the framework of contractual and other legal relationships, due to legal obligations, or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).

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

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

Services and Service Providers Used:

Otherwise, adjust the list of services and providers as needed.

Credit Check

If we provide services in advance or incur comparable economic risks (e.g., for orders on account), we reserve the right to obtain identity and creditworthiness information from specialized service companies (credit agencies) for the purpose of assessing credit risk based on mathematical-statistical procedures, in order to safeguard legitimate interests.

We process the information received from credit agencies about the statistical probability of payment default as part of a reasonable discretionary decision regarding the establishment, execution, and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance services in the event of a negative credit check result.

The decision whether to provide advance services is made, in accordance with Art. 22 GDPR, solely on the basis of an automated individual decision made by our software based on the information from the credit agency.

If we obtain explicit consent from contractual partners, the legal basis for the credit report and the transmission of customer data to credit agencies is consent. If no consent is obtained, the credit report is carried out on the basis of our legitimate interests in the payment security of our claims.

Services and Service Providers Used:

Note: Remove the passage on credit checks if you do not perform credit checks. Review and, if necessary, change the list of service providers. A customer’s creditworthiness can be checked if there is otherwise a risk of payment default, i.e., if the goods are delivered without payment having been received (i.e., if the customer chooses to purchase on account). However, there is no risk of payment default if the customer, for example, chooses the prepayment option or makes payment via third-party providers such as PayPal.

It should also be noted that obtaining an automatic credit report constitutes an “Automated individual decision-making” according to Art. 22 GDPR, i.e., a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified but is often considered to be the case, including by the author of this template.

However, if you want to exclude any risk, you should obtain consent. Consent is also necessary if the credit report is already used to decide whether the “on account” option should be displayed at all. Because it could have been that the customer would have chosen prepayment or PayPal anyway, and the credit check would not have been necessary. Such consent could, for example, read as follows:

 I agree that a credit check will be carried out to decide, in an automated procedure (Art. 22 GDPR), whether the option of purchasing on account is offered. Further information on the credit check, the credit agencies used, the procedure, and the objection options can be found in our [Link]Privacy Policy[/Link].

Provision of Online Services and Web Hosting

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

The data processed in the context of providing the hosting services may include all information relating to the users of our online services that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online services to browsers, and all entries made within our online services or on websites.

Email dispatch and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders, as well as other information concerning email dispatch (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of spam detection. Please note that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume responsibility for the transmission path of emails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volume, notification of successful access, 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 can be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability.

Note: If not already done: Please request a so-called “Data Processing Agreement” from the respective web hosters. This is legally required because the hoster collects personal data of website visitors on your behalf.

Contacting Us

When you contact us (e.g., via contact form, email, phone, or social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The response to contact inquiries within the framework of contractual or pre-contractual relationships is made to fulfill our contractual obligations or to answer (pre-)contractual inquiries and otherwise on the basis of legitimate interests in answering the inquiries.

Services and Service Providers Used:

Note: If external CRM systems are used, their providers should be named. Adjust this information or remove the specified service provider. Furthermore, data processing agreements (or “Data Processing Agreements”) must be concluded with the providers. If the providers process user data in a third country, special guarantees must be in place (e.g., Standard Contractual Clauses).

Newsletter and Electronic Notifications

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

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you for a name, for personal address in the newsletter, or other information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. Newsletter registrations are logged to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation times, as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Deletion and Restriction of Processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is simultaneously confirmed. 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 (so-called “blacklist”).

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.

Notes on Legal Bases: Newsletters are sent based on the recipients’ consent or, if consent is not required, based on our legitimate interests in direct marketing, provided and to the extent that this is legally permitted, e.g., in the case of advertising to existing customers. If we commission a service provider to send emails, this is done based on our legitimate interests. The registration process is recorded based on our legitimate interests to prove that it was carried out in accordance with the law.

Content: Information about us, our services, promotions, and offers.

Services and Service Providers Used:

Please delete the newsletter section if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the information on the content of the newsletter and success measurement as needed.

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate visitor flows to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what times our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.

In addition to web analytics, we may also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, viewed content, visited websites and elements used there, and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed depending on the provider.

Users’ IP addresses are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of users (such as email addresses or names) are stored within the framework of web analytics, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Services and Service Providers Used:

Please delete the section on web analytics, monitoring, and optimization if you do not use web analytics, monitoring, and optimization tools on your website. Adjust the list of services and providers as needed.

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on potential user interests, as well as the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which information relevant for the display of the aforementioned content about the user is stored. This information may include, for example, viewed content, visited websites, used online networks, but also communication partners and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

Users’ IP addresses are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no clear data of users (such as email addresses or names) are stored within the framework of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be assigned to the profiles. This is the case if users, for example, are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users may enter into additional agreements with the providers, e.g., by giving consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Services and Service Providers Used:

Please delete the online marketing section if you do not use online marketing tools on your website. Adjust the list of services and providers as needed. Please note that the use of marketing services on the website usually requires a cookie opt-in.

Presences on Social Networks (Social Media)

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

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

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and resulting user interests. These usage profiles can in turn be used to display advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are generally stored on users’ computers, in which user behavior and interests are stored. Furthermore, data independent of the devices used by users can also be stored in the usage profiles (especially if users are members of the respective platforms and are logged in to them).

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

Also, in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

Services and Service Providers Used:

Adjust the list of social networks as needed.

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or social media buttons and posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the users’ IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We strive to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the users’ device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be combined with such information from other sources.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Services and Service Providers Used:

Please delete the section on plugins and embedded functions as well as content if you do not use any plugins or embedded functions or content within your website. Otherwise, adjust the list of services and providers as needed.

Deletion of Data

We delete personal data that we process in accordance with legal regulations as soon as the underlying consent is withdrawn or there are no further legal bases for processing. This applies to cases where the original purpose of processing no longer exists or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

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

Our privacy policy contains additional information on the storage and deletion of data that applies specifically to certain processing operations.

If there are multiple specifications regarding the storage duration or deletion periods of data, the longest period is always decisive. Data that is no longer kept for the originally intended purpose, but due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its storage.

Please select this passage on the storage and deletion of data if your headquarters is in Germany:

Storage and deletion of data according to German law: The following general periods apply to storage and archiving according to German law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 Para. 1 No. 1 in conjunction with Para. 3 AO, § 14b Para. 1 UStG, § 257 Para. 1 No. 1 in conjunction with Para. 4 HGB).
  • 8 years – Accounting vouchers, such as invoices and cost receipts (§ 147 Para. 1 No. 4 and 4a in conjunction with Para. 3 Sentence 1 AO and § 257 Para. 1 No. 4 in conjunction with Para. 4 HGB).
  • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents as far as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price tags, but also payroll documents as far as they are not already accounting vouchers and cash register tapes (§ 147 Para. 1 No. 2, 3, 5 in conjunction with Para. 3 AO, § 257 Para. 1 No. 2 and 3 in conjunction with Para. 4 HGB).
  • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Please select this passage on the storage and deletion of data if your headquarters is in Austria:

Storage and deletion of data according to Austrian law: The following general periods apply according to Austrian law for the storage and archiving of personal data, as far as these are necessary to fulfill legal obligations or to protect legitimate interests:

  • 7 years – Personal data processed in connection with tax-relevant business documents are stored for a period of seven years in accordance with § 132 BAO and §§ 190–212 UGB. This includes, in particular, books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers, invoices, as well as received and sent commercial or business letters and other documents significant for tax collection. The period begins at the end of the calendar year for which the last entry was made and is extended if necessary as long as the documents are relevant for pending tax proceedings.
  • 3 years – Data required for the assertion, exercise, or defense of warranty, damage, or other contractual claims are stored for the duration of the respective applicable statutory limitation period. This is regularly three years according to § 1489 ABGB, provided there are no longer statutory retention obligations.

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us 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.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses can change over time and also at short notice, and we ask you to check the details before contacting them.

Rights of Data Subjects

As a data subject under the GDPR, you are entitled to various rights, which arise in particular from Art. 15 to 21 GDPR:

Definitions of Terms

This section provides an overview of the terminology used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.