1. General Information on Data Processing and Legal Basis

1.1. This privacy policy informs you about the nature, scope, and purpose of the processing of personal data within our online offering and the websites, functions, and content associated with it (hereinafter collectively referred to as “online offering” or “website”). The privacy policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) on which the online offering is operated.

1.2. The terms used, such as “personal data” or its “processing,” refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

2. Types of Data Processed / Categories of Data Subjects

2.1. The personal data of users processed within the scope of this online offering includes:

• Master data (e.g., names and addresses of customers),
• Contact data (e.g., email, telephone numbers),
• Communication data,
• Contract data (e.g., services used, names of contact persons, payment information),
• Usage data (e.g., the web pages of our online offering visited, interest in our products),
• Meta/communication data (e.g., device information, IP addresses), and
• Content data (e.g., entries in the contact form).

2.2. The term “user” encompasses all categories of persons affected by data processing. These include our business partners, customers, prospects, and other visitors to our online offering. The terms used are to be understood as gender-neutral.

2.3. We process personal data of users only in compliance with the relevant data protection regulations. This means that users’ data is processed only when there is legal permission to do so, in particular when data processing is necessary for the provision of our contractual services (e.g., processing of orders) and online services or is required by law, when users have given their consent, or based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation and security of our online offering within the meaning of Article 6(1)(f) GDPR, particularly in reach measurement, creation of profiles for advertising and marketing purposes, and collection of access data and use of third-party services).

2.4. We point out that the legal basis for consent is Article 6(1)(a) and Article 7 GDPR, the legal basis for processing to fulfill our services and implement contractual measures is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR.

2.5. The following persons are affected by data processing:

• Contractual and business partners,
• Users of our online offering,
• Prospects who are interested in our online offering or contact us for other reasons, and
• Customers.

3. Security Measures

3.1. In accordance with Article 32 GDPR, we take appropriate organizational, contractual, and technical security measures in line with the state of the art, taking into account implementation costs and the nature, scope, circumstances, and purposes of data processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of individuals, to ensure an appropriate level of protection for your data. This ensures compliance with data protection laws and protects this data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

3.2. Security measures include, in particular, the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the fact that the URL in your browser’s address bar begins with “https://”. This is a communication protocol that enables data to be transmitted securely through transport encryption.

4. Disclosure of Data to Third Parties and Third-Party Providers

4.1. Data is disclosed to third parties only within the framework of legal requirements. We disclose users’ data to third parties only when this is necessary, for example, on the basis of Article 6(1)(b) GDPR for contractual purposes or on the basis of legitimate interests pursuant to Article 6(1)(f) GDPR in the economic and effective operation of our business.

4.2. We only engage subcontractors to provide our services when we have taken appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of processed personal data in accordance with the relevant legal provisions.

4.3. Insofar as content, tools, or other means from other providers (hereinafter collectively referred to as “third-party providers”) described in this privacy policy are used, we comply with legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

4.4. If we engage a third-party provider whose stated headquarters is located in a third country (outside the European Union or the European Economic Area), it can be assumed that a data transfer to the third-party provider’s country of residence takes place. The transmission of data to third countries only occurs if an adequate level of data protection exists, if users have given their consent, or if there is otherwise legal permission.

5. Provision of Contractual Services

5.1. We process master data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Article 6(1)(b) GDPR. We inform contractual partners before or during data collection, e.g., in online forms, through special marking (e.g., colors) or symbols (e.g., asterisks or similar) or personally, which data is required for the aforementioned purposes. Within the scope of applicable law, we disclose this data to third parties only to the extent necessary for the aforementioned purposes or to fulfill legal obligations or with your consent (e.g., to involved telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities).

5.2. We delete the data after the expiration of statutory warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner within the scope of a contractual relationship in accordance with the provisions of the contract, generally after fulfillment of contractual services.

6. Contact

6.1. When contacting us (via contact form or email), the user’s information is processed to handle the contact request and its processing pursuant to Article 6(1)(b) GDPR. In doing so, we only process the data we need to handle your request.

6.2. Users’ information may be stored in our Customer Relationship Management system (“CRM system”) or comparable inquiry organization.

7. Web Hosting

7.1. In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering 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.

7.2. Based on our legitimate interests within the meaning of Article 6(1)(f) GDPR, we collect data on every access to the server on which this service is located (so-called server log files). Access data includes the name of the web page accessed, file, 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.

7.3. Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of seven days and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident is finally resolved.

7.4. Web hosting services also include sending, receiving, and storing emails. For these purposes, the addresses of recipients and senders, as well as other information regarding email transmission (e.g., the providers involved), including the contents of the respective emails, are processed. Even though our email communication features transport encryption, they are not encrypted on the servers from which they are sent and received. The content of email communication is therefore generally susceptible to manipulation.

8. Cookies & Reach Measurement

8.1. When you visit our website, information may be stored on your computer in the form of a cookie. Cookies are information that is transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Most browsers are set to accept cookies automatically. We would like to point out that use of our online offering without cookies is only possible to a limited extent. In particular, the use of your customer account is generally not possible, as the use of cookies is technically essential for this. However, you can also prevent only certain cookies from being set via your browser (e.g., third-party cookies), for example if you want to prevent web tracking. You can find more information on this in your browser’s help function. Further information on third-party cookies that are set or processed when visiting our website can be found in the following privacy policy, if we use them. We also include other technologies under the term cookies that fulfill the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

• A distinction must be made between cookies that are set by the website operator when visiting a website (also “first-party cookies”) and cookies that are set by third-party providers (also “third-party cookies”). We only have technical control over the former cookies. We further differentiate between the following cookies.
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their browser.
• Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users that are used for reach measurement or marketing purposes can be stored in such a cookie.
• Necessary (also: essential or strictly necessary) cookies: Cookies may be strictly necessary for the operation of a website (e.g., to save logins or other user inputs or for security reasons).
• Statistics, marketing, and personalization cookies: Furthermore, cookies are generally also used in the context of reach measurement and when a user’s interests or behavior (e.g., viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This process is also referred to as “tracking,” i.e., tracking the potential interests of users. We inform you separately about the use of “tracking” technologies in our privacy policy or when obtaining consent.

8.2. We use “session cookies,” which are only stored for the duration of the current visit to our online presence (e.g., to enable the storage of your login status or the shopping cart function and thus enable the use of our online offering at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offering and, for example, log out or close the browser.

8.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.

8.4. The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g., in the business operation of our online offering and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke consent given or to object to the processing of your data by cookie technologies (“opt-out”). You can declare your opt-out first by means of your browser settings by objecting to the setting of cookies in the system settings of your browser. An objection to the use of cookies for online marketing purposes can also be declared by means of 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 can receive further objection notices within the scope of the information on the service providers and cookies used.

Before we process data in connection with the use of cookies or have it processed, we ask users for consent that can be revoked at any time. Before consent is given, only cookies that are necessary for the operation of our online offering are used. Their use is based on our interest and the interest of users in the expected functionality of our online offering. This includes usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Users of our online offering are affected by this processing. The processing is carried out on the legal basis of consent (Article 6(1)(a) GDPR) or legitimate interests within the meaning of Article 6(1)(f) GDPR.

9. Google Analytics

9.1. Based on your consent for the analysis, optimization, and economic operation of our online offering, we use Google Analytics, a web analytics service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses permanent third-party cookies. The information resulting from this is processed exclusively in our interest.

9.2. The information generated by the cookie about users’ use of the online offering is generally transmitted to a Google server in the USA and stored there.

9.3. We have agreed on so-called standard contractual clauses with Google in order to ensure an adequate level of data protection. Google thereby provides a guarantee to comply with European data protection law.

9.4. Google will use this information on our behalf to evaluate users’ use of our online offering, to compile reports on the activities within this online offering, and to provide us with other services associated with the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.

9.5. We only use Google Analytics with activated IP anonymization. This means that users’ IP addresses are shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

9.6. The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offering to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

9.7. Further information on data use by Google, settings, and objection options can be found on Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Data use by Google when you use websites or apps of our partners”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.com/settings/ads (“Manage information that Google uses to show you advertising”).

10. Facebook Social Plugins

10.1. Based on your consent in the interest of optimizing and economically operating our online offering, we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (e.g., videos, graphics, or text contributions) and can be recognized by one of the Facebook logos or are marked with the addition “Facebook Social Plugin”.

10.2. When a user accesses a function of this online offering that contains such a plugin, a direct connection to Facebook’s servers is only established when the user interacts with the plugins. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering by it. User profiles can be created from the processed data. We therefore have no influence on the scope of data that Facebook collects with the help of this plugin and inform users accordingly to the best of our knowledge.

10.3. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offering. If the user is logged into Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by pressing the Like button or leaving a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook obtains and stores their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

10.4. Users can find information on the purpose and scope of data collection and the further processing and use of data by Facebook as well as their related rights and setting options for protecting their privacy in Facebook’s privacy policy: https://www.facebook.com/about/privacy/.

10.5. If a user is a Facebook member and does not want Facebook to collect data about them via this online offering and link it with their member data stored on Facebook, they must log out of Facebook before using our online offering and delete their cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are applied to all devices, such as desktop computers or mobile devices.

11. Reach Analysis with Matomo

11.1. Based on your consent for the analysis, optimization, and economic operation of our online offering, we use Matomo, an open-source software for the statistical evaluation of user access. Users’ IP addresses are shortened before they are stored. However, Matomo uses first-party cookies that are stored on users’ computers and enable an analysis of users’ use of this online offering. Pseudonymous user profiles can be created from the processed data.

11.2. The information generated by the cookie about your use of this online offering is stored on our server and not passed on to third parties.

12. Newsletter

12.1. With the following information, we inform you about the content of our newsletter as well as the registration, dispatch, and statistical evaluation procedures and your right to object. By subscribing to our newsletter, you agree to receive it and the procedures described.

12.2. We send newsletters, emails, and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipients or legal permission. Insofar as the content of a newsletter is specifically described during registration for the newsletter, it is decisive for users’ consent. Otherwise, our newsletters contain information about our products, offers, promotions, and our company.

12.3. Registration for our newsletter 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. Registrations for the newsletter are logged in order 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 dispatch service provider are also logged.

12.4. The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “dispatch service provider”. You can view the dispatch service provider’s privacy policy here: https://www.cleverreach.com/en/privacy-policy/.

12.5. The newsletter is sent using “MailChimp,” a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the dispatch service provider’s privacy policy here: https://mailchimp.com/legal/privacy/. So-called standard contractual clauses have been agreed upon to ensure an adequate level of data protection.

12.6. Furthermore, according to its own information, the dispatch service provider may use this data in pseudonymous form, i.e., without assignment to a user, to optimize or improve its own services, e.g., for technical optimization of dispatch and presentation of newsletters or for statistical purposes, to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to contact them itself or to pass it on to third parties.

12.7. Registration data: To register for the newsletter, it is sufficient if you provide your email address. Optionally, we ask you to provide a name for personal address in the newsletter.

12.8. The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from the dispatch service provider’s server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected. This information is used to technically improve services based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. Statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

12.9. The use of the dispatch service provider, implementation of statistical surveys and analyses, and logging of the registration procedure are based on our legitimate interests pursuant to Article 6(1)(f) GDPR. Our interest is directed toward the use of a user-friendly and secure newsletter system that serves both our business interests and meets users’ expectations.

12.10. You can cancel receipt of our newsletter at any time, i.e., revoke your consent. This simultaneously terminates your consent to its dispatch by the dispatch service provider and the statistical analyses. Unfortunately, a separate revocation of dispatch by the dispatch service provider or the statistical evaluation is not possible. You will find a link to cancel the newsletter at the end of each newsletter. If users have only registered for the newsletter and have canceled this registration, their personal data will be deleted.

13. Integration of Videos

13.1. To display submitted contributions, we use videos. Since local hosting of videos is not powerful enough, we use external video providers. We use the services of Vimeo, Inc., West 18th Street, New York 10011, USA (“Vimeo”).

13.2. By integrating the videos, the provider’s servers are accessed. For the associated use of data, we refer to the respective privacy policy of the provider. Vimeo’s privacy policy can be accessed at the following link: https://vimeo.com/privacy.

13.3. The legal basis for the integration of videos and the associated transmission of personal data is Article 6(1)(b) GDPR for registered users of our offering. The integration is necessary because there is currently no comparable video solution available to provide protected videos.

13.4. For non-registered users, the legal basis for the transmission of personal data is Article 6(1)(f) GDPR.

13.5. To ensure an adequate level of data protection when transmitting data to the USA, we have concluded the so-called standard contractual clauses with the provider of Vimeo. As a further protective measure, we generally integrate videos in the “Do Not Track” variant, so that the scope of transmitted personal data is reduced to a minimum.

13.6. Alternatively, we can also use the service provider YouTube. Videos from the “YouTube” platform of the third-party provider Google. The video is embedded in our website but continues to be hosted on the YouTube platform. When the video is played, a connection is established with YouTube. The privacy policy can be accessed here: https://www.google.com/policies/privacy/ and you can find an opt-out here: https://www.google.com/settings/ads/.

14. Integration of Third-Party Services and Content

14.1. Within our online offering, based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR) or based on your consent (Article 6(1)(a) GDPR), we use content or service offerings from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This is done to provide our online offering and to create user-friendliness of our online offering. This always presupposes that the third-party providers of this content perceive users’ IP addresses, as they could not send the content to their browsers without the IP address. The IP address is therefore necessary for the presentation of this content. We endeavor to use only content whose respective providers use the IP address only to deliver 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. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in third-party cookies on users’ devices 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 linked to such information from other sources.

14.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy policies, which contain further information on data processing and, in some cases already mentioned here, objection options (so-called opt-out):

• If our customers use third-party payment services (e.g., PayPal or Sofortüberweisung), the terms and conditions and privacy policies of the respective third-party providers apply, which can be accessed within the respective websites or transaction applications.
• External fonts from Google Ireland, https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done by a server call to Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/. You can find an opt-out here: https://www.google.com/settings/ads/.
• Maps from the “Google Maps” service of the third-party provider Google. The privacy policy can be accessed here: https://www.google.com/policies/privacy/. You can find an opt-out option here: https://www.google.com/settings/ads/
• Our online offering uses functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Each time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn’s servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click the “Recommend Button” on LinkedIn and are logged into your LinkedIn account, it is possible for LinkedIn to associate your visit to our website with you and your user account. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by LinkedIn. The privacy policy can be accessed here: https://www.linkedin.com/legal/privacy-policy and an opt-out is available here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Functions of the Twitter service may be integrated within our online offering. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. By using Twitter and the “retweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter. We point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy can be found at http://twitter.com/privacy. You can change your privacy settings on Twitter in the account settings at http://twitter.com/account/settings.
• We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages containing XING functions is accessed, a connection to XING’s servers is established. To our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated. Privacy policy: https://www.xing.com/app/share?op=data_protection.

15. Rights of the Data Subject

If personal data concerning you is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

15.1. Right of Access
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you may request information from the controller about the following:

• the purposes for which the personal data is being processed;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
• the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
• the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
• the existence of a right to lodge a complaint with a supervisory authority;
• all available information about the origin of the data if the personal data is not collected from the data subject;
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and—at least in these cases—meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

15.2. Right to rectification
You have the right to rectification and/or completion vis-à-vis the controller if the personal data concerning you that is being processed is inaccurate or incomplete. The controller must carry out the rectification without undue delay.

15.3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:

• if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• if the processing is unlawful and you oppose the erasure of the personal data and request the restriction of the use of the personal data instead;
• if the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; or
• if you have objected to processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the controller’s legitimate grounds override your grounds.

Where the processing of personal data concerning you has been restricted, such data may—apart from being stored—only be processed with your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been imposed under the above conditions, you will be informed by the controller before the restriction is lifted.

15.4. Right to erasure
a) Obligation to erase
You may request that the controller erase personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay where one of the following grounds applies:

• The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
• The personal data concerning you has been processed unlawfully.
• The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data concerning you was collected in relation to the offer of information society services pursuant to Art. 8(1) GDPR.

b) Information to third parties
Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17(1) GDPR to erase it, the controller shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers processing the personal data that you, as the data subject, have requested the erasure by such controllers of any links to, or copies or replications of, that personal data.

c) Exceptions
The right to erasure does not apply insofar as the processing is necessary

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Art. 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
• for the establishment, exercise or defence of legal claims.

15.5. Right to be informed
If you have asserted your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom the personal data concerning you has been disclosed of such rectification or erasure of the data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.

15.6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data has been provided, provided that

• the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR; and
• the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be adversely affected thereby.

The right to data portability does not apply to processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

15.7. Right to object
You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

In connection with the use of information society services—regardless of Directive 2002/58/EC—you may exercise your right to object by automated means using technical specifications.

15.8. Right to withdraw consent under data protection law
You have the right to withdraw your declaration of consent under data protection law at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent up to the time of withdrawal.

15.9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• is necessary for entering into, or performance of, a contract between you and the controller,
• is authorised by Union or Member State law to which the controller is subject and that law provides for suitable measures to safeguard your rights and freedoms and your legitimate interests; or
• is based on your explicit consent.

However, such decisions may not be based on special categories of personal data pursuant to Art. 9(1) GDPR, unless Art. 9(2)(a) or (g) applies and suitable measures to protect your rights and freedoms and your legitimate interests have been taken.

With regard to the cases referred to in (1) and (3), the controller shall implement suitable measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view, and to contest the decision.

15.10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform the complainant of the status and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

16. Erasure of data

16.1. The data stored by us will be erased as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent erasure. Erasure will also take place in particular if other legal permissions cease to apply. If users’ data is not erased because it is required for other legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to users’ data that must be retained for commercial or tax law reasons.

16.2. In accordance with statutory requirements, retention is for 6 years pursuant to Section 257(1) HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years pursuant to Section 147(1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).

17. Right to object

Users may object to the future processing of their personal data at any time in accordance with statutory requirements. The objection may in particular be made against processing for direct marketing purposes.

18. Changes to this Privacy Policy

18.1. We reserve the right to amend this Privacy Policy in order to adapt it to changes in the legal situation, or to changes to the service and data processing. However, this applies only with regard to statements on data processing. If users’ consent is required or if parts of the Privacy Policy contain provisions governing the contractual relationship with users, the changes will be made only with users’ consent.

18.2. Users are requested to regularly inform themselves about the content of this Privacy Policy.