Privacy Notice
Compliance with data protection regulations is very important to PAUL HARTMANN AG (hereinafter referred to as "HARTMANN", "we" or "us"). We would therefore like to inform you in the following about the processing of your personal data, in particular about the purposes of the respective data processing and the data categories processed, subdivided according to individual services or forms of use and about the rights to which you are entitled. With regard to the related terms, such as "personal data" or "processing", we refer to the relevant definitions in Art. 4 General Data Protection Regulation (GDPR).
If you are a shareholder, customer, supplier of or applicant at HARTMANN, you will find information on the processing of your personal data here:
Shareholders can find more information here
Customers can find more information here
Suppliers can find more information here
Applicants can find more information here
We kindly ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration 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 a cooperative action on your part (e.g. consent) or other individual notification.
Status: 24.06.2024
Responsible party:
PAUL HARTMANN AG
Paul-Hartmann-Straße 12
89522 Heidenheim
Phone: +49-7321-36-0
Fax: +49-7321-36-3636
E-Mail: info@hartmann.info
Contact Data Protection:
PAUL HARTMANN AG
Department DPM / DPO
Paul-Hartmann-Straße 12
89522 Heidenheim
E-Mail: datenschutz@hartmann.info
Do you have general questions or comments about this data protection declaration or specific questions about the processing of your data? We will gladly answer them.
In accordance with Art. 13, 14 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not expressly mentioned in this data protection declaration, the following applies:
The legal basis for obtaining consent is Article 6 (1) a and Article 7 GDPR as well as Article 9 (2) a and Article 7 GDPR (e.g. registration on offered portals/creation of customer accounts, delivery of user-specific offers and information about our products and services, surveys on our websites, analysis of the use of our products, services and websites, personalisation of offers on the Internet, by e-mail, fax and other channels, advertising or market and opinion research), the legal basis for processing for the purpose of fulfilling our services and carrying out contractual measures and responding to enquiries is Art. 6 (1) b GDPR (e.g. registration on offered portals/creation of customer accounts, execution of contract and/or service, processing of payments for purchases and other services (e.g., SEPA direct debit), processing due to a complaint, communication in particular via telephone, e-mail, fax, live chat, video call, supply advice), the legal basis for processing for the fulfilment of our legal obligations is Art. 6 (1) c GDPR (e.g. compliance with the statutory retention periods) and the legal basis for processing to safeguard our legitimate interests listed below is Art. 6 (1) f GDPR (e.g. Analysis and clarification of misuse or attacks on communication systems, legitimation and authentication; protection against or investigation of possible fraudulent transactions, communication via telephone, e-mail, fax, live chat, video call and other channels; sending samples, premiums, products and information, providing user-specific offers and information about our products and services, surveys on our websites, personalisation of offers on the Internet, by e-mail, fax and other channels, determining the effectiveness of our advertising). In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) d GDPR serves as the legal basis. The processing of health data that has obviously been made public (or other special categories of personal data) is based on Art. 9 (2) e GDPR.
In accordance with Articles 24, 32 GDPR, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons. Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to personal data, as well as access, input, disclosure, safeguarding of availability and segregation thereof. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of personal data and response to threats to personal data. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and procedures, in accordance with the principle of data protection by means of technological design and by means of data protection-friendly presettings (Art. 25 GDPR).
The security measures include in particular the encrypted transmission of data between your browser and our server. Third party security measures include in particular IP masking (pseudonymization of your IP address).
Due to close cooperation in some areas, we may also process your personal data together with another data controller within the meaning of Art. 26 GDPR. The respective partners are determined by the individual cooperation with regard to the purposes presented below. Information on how the partners process your personal data can be found in their data protection declarations. In order to guarantee your rights in particular and taking into account the requirements of the GDPR, we have concluded an agreement on a case-by-case basis that sets out rules for the processing of your personal data. Thus, as so-called joint controllers, we are jointly responsible for the processing of your personal data.
4.1. Purposes of data processing within the framework of joint controllership
Joint controllership in the context of processsing of your personal data can take place fort he following purposes:
- Integration of our services on third-party websites, e.g. integration of wizards, plug-ins or other technical means;
- Integration of third-party services on our websites, e.g. integration of wizards, plug-ins or other technical means;
- Offering products and services on third-party marketplaces;
- Carrying out surveys, investigations, and their evaluation;
- Carrying out audit procedures (e.g. as part of audits);
- Implementation and use of a whistleblower system.
4.2. Categories of data processed under a joint controllership
In particular, we process the following categories of personal data:
- Inventory data (e.g. first and last name);
- Contact information (e.g. phone number, email address);
- Contract data (e.g. billing data);
- Payment data (e.g. account data);
- Special categories of personal data (e.g. health data);
- Content data (e.g. communication content);
- Metadata (e.g. IP address).
4.3. Contact information to exercise your rights
In individual cases, together with our respective partners, we have agreed on how we will ensure your rights and specified in more detail which obligations are incumbent on each partner to fulfill the obligations of the GDPR. It is particularly relevant to ensure that your rights as data subjects are exercised and that the information obligations to you in accordance with Articles 13 and 14 of the GDPR are fulfilled. We will be happy to answer general inquiries or comments using the contact details provided in section 1 of this privacy notice. To exercise your rights, please use the form linked in section 14 of this privacy notice.
Regardless of the determined contact point, you can also assert your rights directly against the respective partner.
Note: Insofar as your personal data is processed by a partner – going beyond the scope of joint responsibility – you are free to exercise your rights against this partner.
If, in the course of our processing, we disclose (third parties) personal data to other persons and companies - including Group companies -, transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorisation (e.g. if a transfer of the data to third parties, such as to payment service providers, is necessary for the performance of the contract in accordance with Art. 6 (1) b GDPR), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosters, etc.).
Insofar as we commission so-called contract processors with the processing of personal data on the basis of a so-called "data processing agreement" and thereby secure for ourselves, among other things, the necessary powers of influence or control with regard to the processing and use of personal data, this is done on the basis of Art. 28 GDPR. However, we remain responsible to you for the legality of the data processing.
If we process personal data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or if personal data is disclosed or transferred to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or transfer personal data in a third country only if the special prerequisites of Art. 44 ff. GDPR. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised establishment of a data protection level equivalent to that of the EU or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").
This information informs you about the type, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and contents as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offer“). You can find further information in our “Privacy Notice Customers”.
7.1 Cookies, analysis, tracking, optimisation
Information on the cookies we use is mainly found in our cookie policy. Information on technologies from us or from third parties, which are not only used to provide a function within our online offer, but also exclusively or additionally serve the analysis of user behaviour, tracking, the optimisation of our marketing activities or other purposes, is made available to you in this data protection declaration and in our cookie policy.
7.2 Purposes of data processing
We process your personal data in particular for the following purposes:
Provision of the online offer, its contents and functions; marketing, advertising, public relations and market research; security measures; tracking (e.g. interest/behavioural profiling, use of cookies); remarketing; visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles); version measurement (measurement of the effectiveness of marketing measures); target group formation (determination of target groups relevant for marketing purposes or other output of content); cross-device tracking (cross-device processing of user data for marketing purposes).
7.3 Categories of data
We process in particular the following data categories:
Usage data (e.g. websites visited, services used, interest in content, access times); meta/communication data (e.g. device information, IP addresses, browser type); location data (data indicating the location of an end user's end device).
7.4 Collection of access data and log files
On the basis of our legitimate interests within the meaning of Art. 6 (1) f GDPR, we collect data on every access to the server on which this service is located (so-called server log files). The access data includes the path of the website accessed, files linked to it, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider as well as other browser header data. In particular, the processing of your IP address as personal data is necessary for communication between your browser and our server.
Log file information is stored for a period of 6 months for security reasons (e.g. for the clarification of abuse or fraud) and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until final clarification of the respective incident. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) c GDPR.
7.5 Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing social networks and platforms, the terms and conditions and data processing guidelines of the respective operator apply.
We process your personal data if you communicate them within social networks and platforms, e.g. by writing articles on our online presences or sending us messages. In addition, Meta platforms, among other things, may provide statistics and insights (e.g., total number of page views, "Like" information, page activity, post interactions, video views, post reach, comments, shared content, responses, etc.) that help us understand the types of actions you take on our sites. This enables us to better understand your interests and preferences and can, for example, increase the attractiveness of articles or our performance presentation or choose the right time for publication.
We point out that your personal data may be processed by the respective operator outside the European Union or the European Economic Area (third country).. As a result, risks may arise for you, in particular the enforcement of rights may become more difficult. However, processing in a third country is always dependent on the existence of the special requirements of Art. 44 et seq, it means the processing takes place e.g. on the basis of special guarantees, such as the officially recognized level of data protection protection corresponding to the level of the EU or in compliance with officially recognized contractual obligations (so-called "standard contractual clauses").
If you click on the button of the respective operator, you will be redirected to our respective online presence in a separate browser window and can - if you are logged in to your user account - share or subscribe to our news, among other things. Clicking the button will establish a direct connection between your browser and the server of the respective operator. The respective operator receives the information that you have visited our website with your IP address. The respective operator may collect further personal data as soon as you use their offers. In addition, it is then possible for the respective operator to assign your visit to our website to you and your user account, provided you are logged in to your user account.
In addition, your personal data may be further processed for the purposes of market research and advertising. This means that profiles can be created from your usage behaviour and the preferences and interests derived from it. Such profiles can be used, for example, to place suitable advertisements within our online presence or on other online presences or websites based on the interests determined. Cookies are placed and stored on your end device, with the help of which personal data on usage behaviour can be collected and bundled for further processing - to determine your interests. The collection and bundling of this personal data can - especially if you are logged in to your user account - also be realised across several end devices used by you.
The processing of your personal data is based on our legitimate interest in effective information and performance presentation and direct communication with you in relation to our online offer in accordance with Art. 6 (1) f GDPR.
Should you request information or wish to exercise other rights to which you are entitled, please contact the respective operator directly. The background to this is that only the respective operators have access to your personal data and can provide you with the relevant information and take further measures if necessary. Should you require assistance in exercising the rights to which you are entitled, you can also contact us at any time.
A description of the data processing carried out by the respective operator as well as the requirements for the implementation of an objection (opt-out) can be found in the information provided by the respective operator:
Provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://www.facebook.com/about/privacy/
Site insight data: https://www.facebook.com/legal/terms/information_about_page_insights_data
Opt-Out: https://www.facebook.com/settings?tab=ads
Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland
Privacy policy: https://twitter.com/de/privacy
Opt-Out: https://twitter.com/personalization
Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA
Privacy policy: https://www.linkedin.com/legal/privacy-policy
Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy policy: https://privacy.xing.com/en/privacy-policy
Provider: YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA
Privacy policy: https://policies.google.com/privacy?hl=de&gl=de
Provider: (Instagram) Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://help.instagram.com/519522125107875
Provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Irland
Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE
Opt-Out: https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data/personalization-and-data
7.6 Links
We do not use social plug-ins from social networks that collect personal data on our websites. We only use links on our websites to social networks. This prevents our users' personal data from being passed on to social networks without their knowledge when they visit our websites. The links establish a connection to our online presence of the respective social network exclusively on request - therefore only after the user clicks on a link. After a click on the link, the IP address and the general header information of the browser of the user's browser are transmitted to the respective social network. The respective social network may collect further personal data as soon as you use its offers. For example, if you are logged into your account, Facebook may associate your visit with your account. We would like to point out that we have no knowledge of the content of the personal data transmitted in the further course of the process, nor of its use by the social networks.
The links described above are used for the following social networks:
Provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://www.facebook.com/about/privacy/
Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland
Privacy policy: https://twitter.com/de/privacy
Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA
Privacy policy: https://www.linkedin.com/legal/privacy-policy
Provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy policy: https://privacy.xing.com/en/privacy-policy
Provider: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://help.instagram.com/519522125107875/
Provider: Aut O’Mattic A8C Ireland Ltd.,Business Centre, No.1 Lower Mayor Street, International Financial Services Centre, Dublin 1, Ireland
Privacy Policy: https://www.tumblr.com/privacy/de
Opt-Out: https://www.tumblr.com/login?redirect_to=%2Fsettings%2Fprivacy
When you communicate with us by means of a video conference, we and the provider of the respective video conference platform (hereinafter referred to as "platform(s)") process your personal data. With the following specific data protection declaration, we inform you about the processing of your personal data within the scope of use.
8.1 Purposes and legal basis
We use platforms, for example, to offer certain services (e.g., conducting webinars or training courses, etc.) or simply to enable communication (internal and external). The use of the platforms, along with other related purposes, is therefore necessary for the provision of our services and, in principle, for the performance of contracts (cf. Art. 6 (1) b GDPR, § 26 (1) BDSG).
In addition, the use of the platforms is regularly in our legitimate interest (cf. Art. 6 (1) f GDPR), as it simplifies the implementation or provision of our services and accelerates communication (internally and externally) or makes it possible in the first place, especially if face-to-face events are not possible. In the context of the provision of use, it may also be in our legitimate interest to carry out troubleshooting and generate evaluations.
Furthermore, the platforms may also be used based on a consent (cf. Art. 6 (1) a GDPR), in particular in connection with any recording within the scope of use. We will inform you about this separately in advance, in particular about the personal data processed in connection with the recording (e.g., recording of image and spoken contributions or transcription of these).
8.2 The processed (personal) data
When using platforms, we process (personal) data. Which (personal) data is processed and to what extent depends in particular on the service offered, the platform used, the technical functions used and the information you provide before, during or after participating in a meeting, e.g., a webinar. During a meeting, content may therefore also be exchanged, uploaded, or otherwise made available. Typically, we process the following (personal) data in particular:
Meeting participant details: To participate in a meeting or to enter the meeting room, at least the first and last name must usually be entered (depending on the platform used). Under certain circumstances, it is also possible to provide only a pseudonym. In addition to the first and last name, we process the email address and the access password to the meeting, optionally the profile picture and the telephone number.
If necessary, the data will be processed after the meeting for further purposes (e.g., issuing attendance confirmations). As a rule (depending on the platform and configuration used), the information is deleted 30 days after the end of the meeting. More information on the duration of the storage of personal data and on deletion can be found below under No. 5.
Metadata: The following metadata may be generated during a meeting: Time and date of meeting, duration of meeting, interruptions of meeting, log-in and log-out time(s), measurement of behaviour in the meeting, e.g., share of speech (optional), participant IP addresses, information on hardware and software used.
If necessary, metadata is used after the meeting for troubleshooting or evaluation purposes, among other things. Metadata is usually deleted 30 days after the end of the meeting (depending on the platform and configuration used). More information on the duration of the storage of personal data and on deletion can be found below under No. 5.
Text, audio, and video data: It is possible (if the function is enabled) to use the chat, question or poll function in a meeting. Text entries are processed to display them in the meeting and, if necessary, to record them. In addition, to enable the display of video and the playback of audio, (personal) data from the video camera and microphone of the terminal device are processed during the meeting. The video camera and/or microphone can be switched off or muted at any time.
After the meeting, text, audio and video data are only processed for a specific purpose (e.g., subsequent provision of a link to view the webinar). After the purpose has ceased to exist (e.g., expiry of the validity of the link), the data is generally deleted unless another purpose justifies the processing. More information on the duration of the storage of personal data and on deletion can be found below under no. 5.
Recording, storage: Optionally, video, audio and presentation recordings or, if necessary, a transcription of the spoken word are made. Recordings require that the camera and microphone are switched on, that the screen is shared if necessary and that the resulting functions are also used. The transcription can also be used anonymously (depending on the platform and configuration used).
If the chat function is also used, the information you provide will be saved in the text file of the meeting chat. This also applies to sent files.
Recordings or other stored data are only processed after the meeting if this is necessary to achieve the purpose (e.g., subsequent provision of a link to view the webinar). If the purpose ceases to apply (e.g., expiry of the validity of the link), the recordings or other stored data will generally be deleted unless a further purpose justifies the processing. More information on the duration of the storage of personal data and on deletion can be found below under No. 5.
Dial-up with the telephone: As a rule, the telephone number and country are processed, optionally - location and connection data.
If necessary, dial-in data is used after the meeting, e.g., for troubleshooting or evaluation. They are usually deleted 30 days after the end of the meeting (depending on the platform and configuration used). More information about the duration of storage of personal data and deletion can be found below under No. 5.
8.3 Platforms used, recipients of the (personal) data
To fulfil the aforementioned purposes, we currently use the following platforms in particular: Teams and Skype from Microsoft, GoToMeeting from LogMeIn, WebEx from Cisco and Zoom from Zoom Video Communications.
The data protection declarations of the platform providers (hereinafter "providers"), with each of which we have concluded a commissioned processing agreement in accordance with Art. 28 GDPR, can be found here:
Teams and Skype from Microsoft:
https://docs.microsoft.com/de-de/microsoftteams/teams-privacy
GoToMeeting from LogMeIn:
LogMeIn (USA) Privacy Policy
WebEx from Cisco:
Cisco Online Privacy Statement - Cisco
Zoom by Zoom Video Communications:
Data protection | Zoom
Within our company, (only) those internal offices or employees receive personal data insofar as they need it to fulfil the aforementioned purposes in particular (enabling communication via a platform by creating a meeting). However, the data recipients are obliged in each case to use personal data only to the extent necessary.
If we transmit personal data to other (external) persons, companies or other third parties (e.g., downstream transmission of the recording of the meeting to participants) or grant them other access to personal data, this is only done on the basis of a legal permission or a corresponding consent. If we commission third parties with the processing of personal data based on a so-called "order processing agreement" and thereby secure for ourselves, among other things, the necessary powers of influence or control with regard to the processing and use of personal data, this is done on the basis of Art. 28 GDPR. However, we remain responsible to you for the lawfulness of the data processing. In this context, we also ensure that the providers maintain appropriate technical and organisational measures to protect the personal data.
In addition, providers may also process personal data for their own purposes. Please note that in this case, the providers themselves are responsible and must fulfil the obligations arising from the GDPR (e.g., obligation to inform, obligation to delete after the purpose has been achieved, etc.). Further information can be found in the data protection declarations of the providers (see above).
8.4 Processing of personal data in a third country
As far as possible, we will carry out the processing of personal data on the territory of the Federal Republic of Germany, in another member state of the European Union or in another state party to the Agreement on the European Economic Area (e.g., store (have stored) the data arising during use in an "EU cluster").
However, if processing of personal data in third countries (e.g., USA) is necessary, in particular in connection with the commissioning of providers, we will ensure that the specific legal requirements for such processing operations are met and thus that an adequate level of data protection exists in the respective third country. This includes, in particular, checking whether the European Commission has decided that an adequate level of protection exists in a third country (cf. Art. 45 GDPR) or whether suitable or adequate safeguards (e.g., standard contractual clauses) are in place and the enforcement of your rights is guaranteed as well as whether sufficient technical and organisational measures are in place to protect the personal data.
For further information on the appropriate or adequate safeguarding measures and how and where to obtain a copy of them, please contact datenschutz@hartmann.info.
8.5 Duration of the storage of personal data, deletion
In principle, we process and store personal data for the duration of a meeting or webinar and any subsequent services/processes (e.g., issuing certificates of attendance, providing the link to a webinar or the transcription, etc.). In addition, we may also process or store personal data for other purposes, e.g., for troubleshooting and evaluation purposes.
If the processing or storage is no longer necessary, we delete the personal data. This does not apply if, among other things, legally prescribed retention periods prevent the deletion (cf. Art. 17 (3) GDPR) and/or another case of Art. 17 (3) GDPR exists and/or a new purpose justifies further processing.
Incorrect and/or incomplete data will be deleted or - as far as possible - corrected without delay in accordance with Art. 5 (1) d GDPR.
8.6 Technical and organisational measures
To ensure that personal data is protected, the following technical and organisational measures are taken in particular:
- User authentication;
- Possibility for two-factor authentication (e.g., in Zoom and MS Teams);
- Transport / end-to-end encryption;
- Possibility to pixelate backgrounds after activating the camera;
- Possibility of participation with video/sound off by default;
- Participation without creation of an account (guest account);
- Participation without installation of an application (web client);
- Recording and storage turned off by default, recording only started after consent.
8.7 Further data protection information
Further information on the processing of your personal data, in particular your rights, can be found in the applicable / valid data protection declaration for you as an employee, customer, supplier, etc., available on the intranet or on our website, among other places.
When you contact us (by contact form, telephone, fax, post or e-mail), your personal data will be processed for the purpose of handling your enquiry and its processing in accordance with Article 6 (1) a) (consent - withdrawal possible at any time), lit. b) (service provision) and lit. f) (legitimate interests - objection possible) GDPR. The information marked as mandatory in the contact form is required for the processing of your enquiry.
As a rule, we delete inquiries 3 months after their receipt, at the latest, however, if they have been answered. If you have withdrawn your consent, we will delete your data at this time. In the event of statutory storage obligations to be observed, the deletion shall take place after their expiry.
We maintain blogs with the possibility of commentary in our online offer. For the comment function, in addition to your comment, information on the time of the creation of your comment, your e-mail address and, if you are not anonymous, the user name you have chosen are stored. Comments remain in the blog as long as it is operated or you request its deletion.
If you write a comment, your IP address will be stored for 6 months on the basis of our legitimate interests in the sense of Art. 6 (1) f GDPR in addition to the time of creation, and then deleted. This is done for our security, as far as in individual cases illegal contents are left behind in comments (e.g. insulting contents, forbidden political propa-ganda, etc.) which require clarification, in particular the determination of the identity of the author. We will delete comments with the aforementioned content immediately. Should the further storage of your IP address and the time of creation of the respective comment be necessary for evidence purposes, these (personal) data are excluded from deletion until the final clarification of the respective incident. This (personal) data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 (1) c GDPR.
With the following notes we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your right of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send e-mails and other (electronic) notifications with advertising information (hereinafter "newsletter") only with your consent or on the basis of a legal permission. If the contents of the newsletter are specifically rewritten within the scope of a registration for the newsletter, they are decisive for the consent. Furthermore, our newsletters contain information about our products, offers, promotions and our company.
Newsletters are sent by us or by a service provider where required.
Logging double opt-in and changes: The registration to our newsletter is done in a so-called Double-Opt-In-Procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your (personal) data stored by the shipping service provider are also logged.
According to its own information, the delivery service provider may use your (personal) data in pseu-dononymous form, i.e. without allocation to a user, to optimise and improve its own services, e.g. for technical optimisation of the delivery and presentation of newsletters or for statistical purposes to determine from which countries the recipients come. However, the dispatch service provider does not use your (personal) data to write to you itself or to pass on your (personal) data to third parties.
Registration data: To subscribe to the newsletter, you only need to enter your e-mail address. Optionally we ask you - for personal contact - to enter your first and last name.
Performance measurement: The newsletters contain a so-called "web beacon". This is a pixel-sized file that is retrieved from the server of the mailing service provider when the newsletter is opened. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used in particular for the technical improvement of the services and to determine your reading habits. Statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. This information can be assigned to you for technical reasons.
The dispatch of the newsletter and the measurement of success are based on your consent in accordance with Art. 6 (1) a, Art. 7 GDPR in conjunction with § 7 (2) No. 3 of the German Act against Unfair Competition (UWG). The registration procedure is recorded on the basis of our legitimate interests in accordance with Art. 6 (1) f GDPR and serves as proof of your consent to receive the newsletter.
Withdrawal: You can withdraw the receipt of our newsletter at any time. You will find a link to withdraw the receipt of our newsletter at the end of each newsletter. Your (personal) data will be deleted in case of a withdrawal.
On our website and within our online offering, we use content or service offerings from third parties. This happens based on our legitimate interests (interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 (1) f GDPR) for processing of a contract on the basis of Art. 6 (1) b GDPR or based on your consent according to Art. 6 (1) a GDPR. This requires the third party providers to be aware of your IP address, as without the IP address they would not be able to send the Content to your browser. The IP address is therefore required for the display of content. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information such as visitor traffic on the website. The pseudonymous information can also be stored in cookies on your device and may contain technical information about the browser and operating system, referring websites, visiting time and other details about the use of our online offer, as well as being linked to such information from other sources.
In the following presentation we have compiled an overview of third party providers (payment service provider are listed separately) together with their offered contents as well as links to their data protection declarations, which may contain further information on the processing of data as well as information on objection. Please note that we have listed further third-party providers as well as further information on the third-party providers mentioned here in our cookie policy.
Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland
Privacy policy: https://twitter.com/de/privacy
Opt-Out: https://twitter.com/personalization
Provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA
Privacy policy: https://www.linkedin.com/legal/privacy-policy
Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Within our online offer we use the conversion tool "LinkedIn Insight Tag". This tool creates a cookie in your web browser, which enables the collection of data. Based on the collected data, LinkedIn creates anonymous reports about the website target group and makes them available to us. LinkedIn also shows us the display performance. In addition, LinkedIn offers the possibility of retargeting via the Insight Tag. We can use this data to display targeted advertising outside of our online offering without identifying you.
Provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany
Privacy policy: https://privacy.xing.com/en/privacy-policy
Provider: (Youtube) Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Privacy policy: https://policies.google.com/privacy?hl=de&gl=de
We have integrated components of YouTube within our online offers. YouTube allows the free posting of video clips and their free viewing, rating and commenting. By calling up one of the individual pages of our online offers on which YouTube content has been integrated, a connection to YouTube is established in order to download the necessary elements for displaying the corresponding video. In doing so, YouTube or the operating company Google receives information about which subpage within our online offers has been called by the respective user. In addition, further information, such as the IP address, the browser used, the operating system and technical device information, date and duration of the visit are forwarded. If the user is logged on to YouTube at the time of visiting our online offers with the same device, YouTube recognizes the user by calling up a single page that contains a YouTube video. This occurs regardless of whether the person concerned clicks on a YouTube video or not. This information can be aggregated by YouTube or Google and assigned to the profile of the respective user, unless the elements have been integrated in "privacy mode". We always use the "Privacy Mode", as far as this is possible.
Provider: (Instagram) Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://help.instagram.com/519522125107875
Provider: (Facebook-Pixel) Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland
Privacy policy: https://www.facebook.com/about/privacy/
Opt-Out: https://www.facebook.com/settings?tab=ads
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. The Facebook Pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called "conversion measurement“).
Provider: (Analytics) Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Privacy policy: https://policies.google.com/privacy?hl=de
Terms and Conditions: https://marketingplatform.google.com/about/analytics/terms/us/
Opt-Out: http://tools.google.com/dlpage/gaoptout?hl=de
Further Information on Google Analytics: If you have given your consent, we may use Google Analytics 4, a web analytics service.
Scope of processing: Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected by means of the cookies about your use of this website is generally transferred to a Google server in the USA and stored there.
We may use Google Signals. This allows Google Analytics to collect additional information about users who have personalized ads enabled (interests and demographics) and ads can be delivered to these users in cross-device remarketing campaigns.
Regarding the aforementioned Google functionalities, please consider the following: Google Analytics 4 has IP address anonymization enabled by default. Due to IP anonymization, your IP address will be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. According to Google, the IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
During your website visit, your user behavior is recorded in the form of "events". Events can be:
- Page views
- First visit to a website
- Start of session
- Your "click path", interaction with the website
- Scrolls (whenever a user scrolls to the bottom of the page (90%))
- clicks on external links
- internal search queries
- interaction with videos
- file downloads
- seen / clicked ads
- language settings
Also recorded:
- Your approximate location (region)
- your IP address (in shortened form)
- technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
- your internet service provider
- the referrer URL (via which website/advertising medium you came to our website)
Purposes of processing: On behalf of us, Google will use this information to evaluate your pseudonymous use of our website and to compile reports on website activity. The reports provided by Google Analytics serve to analyse the performance of our website and the success of our marketing campaigns.
Recipients of the data in particular are/may be:
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as processor under Art. 28 GDPR)
- Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
- Alphabet Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
It cannot be ruled out that US authorities may access the data stored by Google.
Third country transfer: Insofar as data is processed outside the EU/EEA and there is no level of adequate data protection corresponding to the European standard according to the GDPR, we have concluded EU standard contractual clauses to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of personal data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against (in particular unlawful) access by authorities.
Duration of storage: The data sent by us and linked to cookies are automatically deleted after 2 or 14 months. The deletion of data whose retention period has been reached occurs automatically once a month.
Legal basis: The legal basis for this data processing is your consent pursuant to Art.6 (1) a) GDPR.
Withdrawal: You can withdraw your consent at any time with effect for the future by accessing the cookie settings/management and changing your selection there. The lawfulness of the processing carried out on the basis of the consent until the withdrawal remains unaffected.
You can also prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may result in a restriction of functionalities on our and other websites. In addition, you can prevent the collection of data generated by the cookie and related to your use of our website (including your IP address) and the (further) processing of this data by Google, by
a. not giving your consent to the setting of the cookie or
b. downloading and installing the browser add-on to disable Google Analytics here.
Provider: (reCAPTCHA) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
To protect our websites or systems from misuse (e.g. spam or other abuse), we can use the "reCAPTCHA" function from Google. This allows us to recognise whether entries etc. are made by humans and not by so-called "bots". In this context, IP addresses and other information about systems used, devices, possibly also the location, the surfing history and the interaction with reCaptcha (also on other websites), e.g. answered questions or selected objects, can be processed.
Provider: (Tag Manager) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
Further Information: https://www.google.com/intl/de/tagmanager/use-policy.html
We may use Google Tag Manager (GTM) to manage website tags via an interface. Tags are small code elements on our website that are used in particular to measure traffic and visitor behaviour, to record the impact of online advertising and social channels, for remarketing and targeting for specific target groups and for testing website areas.
Provider: (Maps) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
Google Maps (Maps) is an online map service that we can offer to search for and display precise locations. The map section of a location can be integrated into a website, e.g. to display directions. When using maps, the search terms entered, the IP address and the coordinates are processed. If the route planner function is also used, the starting address entered is also saved.
Provider: (Ads & Conversion Tracking) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
We may use Google Ads to create offers for our products and services for interest-based advertising. We may also use Google Conversion Tracking (Conversion Tracking) to gain insights into the use of our offers. Conversion tracking provides us with useful information about what happens after a click on an offer, e.g. whether a product is purchased. This allows us to evaluate the success of advertising measures and use the results for optimisation measures. We receive a report from Google with statistical analyses without personal data.
Provider: (Optimize) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
We can use Google Optimize to optimise our website content and therefore also to optimise advertising measures. For example, we check how the content of the website is perceived by users. Based on the feedback, optimisation measures are then taken if necessary.
Provider: (Fonts) Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland
Privacy Policy: https://policies.google.com/privacy
We may use Google Fonts in our online offering, as these can be used across platforms and are web-optimised. When you visit our website, the fonts are loaded by Google. This results in a transfer to Google, whereby Google also recognises your IP address and the fact that you have visited our website, and further information such as language settings, screen resolution of the browser and the name and version of the browser are transmitted. Google may use the data collected to determine the popularity of fonts, for example. Google makes the results available in Google Analytics, for example.
Provider: (Clarity) Microsoft Ireland Operations Ltd, One Microsoft Place, South County Business Park, Leopardstown, Dublin D18 P521, Irland
Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement?tid=136993383
With Microsoft Clarity (Clarity), we can use a solution to monitor the use of our website. This involves recording previously defined website sessions by users of our website, which we can then analyse anonymously. In addition to the IP address, Clarity also records other (meta) data, such as the time of access or mouse movements (cursor and scroll movements).
Provider: Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA
Privacy Policy: https://www.cloudflare.com/de-de/privacypolicy/?tid=311141511
We want to offer you the best possible service with our website. Cloudflare helps us to make our website faster and more secure. Cloudflare provides us with web optimisation as well as security services such as DDoS protection and web firewall. This also includes a reverse proxy and the content distribution network (CDN). Cloudflare blocks threats and limits abusive bots and crawlers that waste our bandwidth and server resources. By storing our website on local data centres and blocking spam software, Cloudflare enables us to reduce our bandwidth usage. Overall, this makes our website significantly more powerful and less susceptible to spam or other attacks.
Provider: Usercentrics A/S, Havnegade 39, 1058 Kopenhagen, Dänemark.
Privacy Policy: https://www.cookiebot.com/de/privacy-policy/
On our website we may use Cookiebot, a cookie consent manager from Usercentrics, to give you control over the cookies used on our website. Cookiebot collects and manages your consents to the use of cookies and other tracking technologies on our website. When you visit our website, Cookiebot will show you a cookie banner where you can select your preferences. Your consent will be stored by Cookiebot so that your preferences will be honoured on future visits to our website. You can review and adjust your consent at any time.
Payment service providers:
We use payment service providers for certain payment services in order to fulfil contracts, due to legal obligations and on the basis of our legitimate interests.
Payment service providers process, for example, your first and last name, your email address, your bank and payment details, your passwords, your TANs, your IP address and other personal data about you. The data is required to carry out transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we generally do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.
Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We currently use the following providers, whereby a technical connection of online payment methods is used:
Provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg
Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
Provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgien
Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html
Provider: Visa Europe Services Inc., Zweigniederlassung London, 1 Sheldon Square, London W2 6TT, GB
Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html
The personal data processed by us will be deleted in accordance with Art. 17 GDPR. Unless expressly stated within the scope of this data protection declaration, the personal data stored by us will be deleted as soon as they are no longer required for their intended purpose and, in particular, there are no legal storage obligations to prevent deletion. If the personal data are not deleted because their processing is necessary for other and legally permissible purposes, the processing is restricted. This means that the personal data is blocked and not processed for other purposes.
Instead of deleting your personal data, we will, if necessary, make it anonymous in such a way that it is irreversibly impossible to retrieve it in the future.
In accordance with the legal requirements, storage takes place in particular for 6 years in accordance with § 257 (1) of the German Commerical Code (HGB) (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 (1) of the German Tax Code (AO) (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
You have the right to withdraw your consent to the processing of your personal data in accordance with Art. 7 (3) GDPR at any time with effect for the future. Processing that has taken place before the withdrawal therefore remains lawful
In accordance with Art. 15 GDPR, you can request information about your personal data processed by us.
In accordance with Art. 16 GDPR, you can demand the immediate correction of incorrect or incomplete personal data stored by us.
In accordance with Art. 17 GDPR, you can request the deletion of your personal data stored with us in accordance with the conditions stated there, unless legally prescribed retention periods prevent immediate deletion (cf. Art. 17 (3) GDPR) and/or another case of Art. 17 (3) GDPR exists and/or a new purpose justifies further processing.
In accordance with Art. 18 (1) GDPR, you can demand the restriction of data processing if one or more conditions in accordance with Art. 18 (1) GDPR lit. a to d apply.
In accordance with Art. 20 (1) GDPR, you can receive the personal data processed by us in a structured, common and machine-readable format and transfer this data to another responsible person without hindrance by us.
In addition, you can lodge an objection to the processing of your personal data in accordance with Art. 21 (1) GDPR. In the event of an objection, we will stop processing your personal data. However, the right of objection only applies if special circumstances arise from your personal situation. In addition, compelling reasons worthy of protection that speak in favour of processing may prevail. Furthermore, certain processing purposes may conflict with your right of objection.
According to Article 21 (2) GDPR, you have the right to object to the processing of your personal data for the purposes of direct marketing at any time and without further conditions. This also applies to profiling, insofar as it relates to such direct advertising. If you lodge an objection, your personal data will no longer be processed for these purposes (cf. Art. 21 (3) GDPR).
Without prejudice to any other administrative or judicial remedy, you also have the right to appeal to the competent supervisory authority (cf. Art. 77 GDPR) if you believe that the processing of your data violates data protection regulations. In this context, however, we would ask you to address a possible complaint to us first. We will then attempt to remedy the situation as quickly and effectively as possible.
To exercise your data subject rights, please use this form.