Skip to main content
Dr. Behr GmbH

Provider

Dr. Behr GmbH
Königswinterer Str. 37a
53227 Bonn
Germany

Contact Options

E-Mail Address: sales@drbehr.com

Phone: +49 (0) 228 976 396 0
Contact form: https://www.drbehr.com/en/contact/

Representatives

Representative/s: Martin Landré, Managing Director; Flurin Beck, Managing Director

Journalistic-Editorial Services

Responsible for content: Martin Landré, Flurin Beck

Company Details

VAT identification number: DE815079945
Terms: https://www.drbehr.com/agb/

Register, Type of Register and Register Number

Commercial Register, administered by: District Court Bonn
Register number: HRB 17065

Social Media Accounts and other Online Profiles

This legal notice also applies to this social media account:

https://www.linkedin.com/company/drbehr/

Reservation of use for text and data mining

The owner of this website permits the use or downloading of content from this website by third parties for the development, training, or operation of artificial intelligence or other machine learning systems (« Text and Data Mining ») exclusively with the express written consent of the owner.

Without such consent, it is prohibited to use the content for Text and Data Mining. This applies even if there are no meta tags on the website that block such processes, and even if bots designed to read the website for Text and Data Mining purposes are not blocked.

Liability and Intellectual Property Rights Information

Liability Disclaimer: While the content of this website has been put together with great care and reflects our current knowledge, it is provided for information purposes without being legally binding, unless the disclosure of this information is required by law (e.g. the legal information), the privacy policy, terms and conditions or mandatory instructions for consumers) .

We reserve the right to modify or delete the content, whether in full or in part, provided this does not affect our existing contractual obligations. All website content is subject to change and non-binding.

Link Disclaimer: We do not accept any responsibility for or endorse the content of external websites we link to, whether directly or indirectly.

The providers of the linked websites are solely responsible for all content presented on their websites and in particular, any damage resulting from the use the information offered on their websites.

Copyrights and Trademarks: All contents presented on this website, such as texts, photographs, graphics, brands and trademarks are protected by the respective intellectual property rights (copyrights, trademark rights). The use, reproduction, etc. are subject to our rights or the rights of the respective authors or rights owners.

Information on legal infringements: Please notify us if you notice any rights violations on our website. Once notified, we will promptly remove any illegal content or links.

Website design, strategy and implementation

Axel Schäfer

Image credits

Image Sources and Copyright Notices:

https://stock.adobe.com
24985085
44593613
61169294
63845148
65502907
66650298
96768426
101562825

https://www.istockphoto.com
106376864
115051315
155432925
173927195
460493629
466753916
474731607
494562664
498548868
499395696
518090962
518656521
527523284
531241452
604824236
655668052
802060942
817031604
817398204
820845254
834505574
908474572
913650676
925440650
959924778
1024678592
1040912074
1069135124
1138137948
1148346394
1161536311
1176126615
1370125530

Privacy Policy

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as « data ») we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as « online services »).

The terms used are not gender-specific.

Last Update: 15. February 2025

Controller

Dr. Behr GmbH
Herr Martin Landré
Königswinterer Str. 37a
53227 Bonn
Deutschland

E-mail address: sales@drbehr.com

Legal Notice: https://www.drbehr.com/en/contact/

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data.
  • Payment Data.
  • Location data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Log data.
  • Creditworthiness Data.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partner.
  • Users.
  • Business and contractual partners.
  • Third parties.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Web Analytics.
  • Targeting.
  • Office and organisational procedures.
  • Conversion tracking.
  • Affiliate Tracking.
  • Organisational and Administrative Procedures.
  • Firewall.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and usability.
  • Assessment of creditworthiness.
  • Information technology infrastructure.
  • Financial and Payment Management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.
  • Artificial Intelligence (AI).

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.

Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as « Swiss DPA »). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).

Reference to the applicability of the GDPR and the Swiss DPA: These privacy policy serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss FADP such as « processing » of « personal data », « predominant interest », and « particularly sensitive personal data », the terms used in the GDPR, namely « processing » of « personal data », as well as « legitimate interest » and « special categories of data » are used. However, the legal meaning of these terms will continue to be determined according to the Swiss FADP within its scope of application.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as « IP masking »). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information that is transferred between the website or app and the user’s browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.

General Information on Data Retention and Deletion

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

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or protection of the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing processes.

In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.

If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.

Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Further information on processing methods, procedures and services used:

  • Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:
    • 10 Years – Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
    • 8 years – Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB))
    • 6 Years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
    • 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).
  • Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
    • 10 years – Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on previous business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire after five years (Article 128 OR).

Rights of Data Subjects

Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DPA:

As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
  • Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as « contractual partners ») within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Online shop, order forms, e-commerce and delivery.: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery, or performance of other services. If necessary for the execution of an order, we use service providers, in particular postal, freight and shipping companies, in order to carry out the delivery or execution to our customers. For the processing of payment transactions we use the services of banks and payment service providers. The required details are identified as such in the course of the ordering or comparable purchasing process and include the details required for delivery, or other way of making the product available and invoicing as well as contact information in order to be able to hold any consultation; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Agency Services: We process the data of our customers within the scope of our contractual services, which may include e.g. conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis / consulting services and training services;
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Business processes and operations

Personal data of service recipients and clients – including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Log data (e.g. log files concerning logins or data retrieval or access times.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Creditworthiness Data (e.g. received credit score, estimated default probability, risk classification based on this, historical payment behaviour). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and other personnel.).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Marketing; Sales promotion; Assessment of creditworthiness; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

  • Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies);
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management);
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting);
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs);
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Purchasing: Processes required in the procurement of goods, raw materials, or services (e.g., selection and evaluation of suppliers, price negotiations, placement and monitoring of orders, inspection and control of deliveries, invoice verification, management of orders, inventory management, creation and maintenance of purchasing policies);
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control);
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Provision of online services and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)); Security measures. Firewall.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a « web hoster »);
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called « server log files ». Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user’s operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
    Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
  • ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities);
    Service provider: ALL-INKL.COM – Neue Medien Münnich, Inhaber: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://all-inkl.com/;
    Privacy Policy: https://all-inkl.com/datenschutzinformationen/;
    Data Processing Agreement: Provided by the service provider.
    Basis for third-country transfers: Switzerland – Adequacy decision (Germany).
  • Sucuri: firewall and security and error detection functions to detect and prevent unauthorized access attempts as well as technical vulnerabilities that could enable such access. For these purposes, cookies and similar storage procedures required for this purpose may be used and security logs may be created during testing and, in particular, in the event of unauthorized access. In this context, the IP addresses of the users, a user identification number and their activities, including the time of access, are processed and stored and compared with the data provided by the provider of the firewall and security function and transmitted to the latter;
    Service provider: Sucuri, LLC., parent company: GoDaddy Media Temple, Inc. d/b/a Sucuri, 6060 Center Dr. Suite 500, Los Angeles CA 90045, USA;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://sucuri.net;
    Privacy Policy: https://sucuri.net/privacy;
    Data Processing Agreement: https://sucuri.net/dpa/.
    Basis for third-country transfers: EEA – Standard Contractual Clauses (https://sucuri.net/dpa/), Switzerland – Standard Contractual Clauses (https://sucuri.net/dpa/).
  • WP Rocket: Caching and loading optimization – Functions that serve to save specific content from websites so that they can be loaded faster on repeated access. This reduces loading times and improves the user experience;
    Service provider: SAS WP MEDIA, Adresse: 4 rue de la République, 69001 LYON, France; L
    egal Basis:     Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://wp-rocket.me/;
    Privacy Policy: https://wp-rocket.me/privacy-policy/;
    Basis for third-country transfers: Switzerland – Adequacy decision (France).
    Further Information: Operating within a self-hosted environment.
  • gstatic.com: Content-Delivery-Network (CDN) – service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://www.google.com/;
    Privacy Policy: https://policies.google.com/privacy;
    Data Processing Agreement: https://business.safety.google/adsprocessorterms.
    Basis for third-country transfers: Switzerland – Adequacy decision (Ireland).

Use of Cookies

The term « cookies » refers to functions that store information on users’ devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.

Information on legal data protection bases: Whether we process personal data using cookies depends on users’ consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.

Storage duration: The following types of cookies are distinguished based on their storage duration:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to the processing according to legal regulations, including through the privacy settings of their browser.

  • Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

  • Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users’ consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users’ devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used;
    Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • BorlabsCookie: Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing;
    Service provider: Executed on servers and/or computers under our controllership;
    Website: https://borlabs.io/borlabs-cookie/.
    Further Information: An individual user ID, language as well as types of consent and the time of their submission are stored on the server and in the cookie on the user’s device.

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability. Marketing.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication;
    Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Gravity Forms: Creation and evaluation of online forms, surveys, feedback forms as well as acceptance of payments and implementation of automated workflows;
    Service provider: Executed on servers and/or computers under our controllership;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
    Website: https://www.gravityforms.com/.

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term « AI system » as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as « AI providers »). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties.
  • Purposes of processing: Artificial Intelligence (AI).
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions (« AI », meaning « Artificial Intelligence » shall be construed in the applicable legal sense of the term);
    Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://openai.com/product;
    Privacy Policy: https://openai.com/policies/privacy-policy/;
    Basis for third-country transfers: Switzerland – Adequacy decision (Ireland).
    Opt-Out: https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
  • DeepL: Translation of texts into various languages and provision of synonyms as well as context examples. Support with the correction and improvement of texts in different languages;
    Service provider: DeepL SE, Maarweg 165, 50825 Köln, Germany;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://www.deepl.com;
    Privacy Policy: https://www.deepl.com/en/privacy;
    Data Processing Agreement: Provided by the service provider.
    Basis for third-country transfers: Switzerland – Adequacy decision (Germany).

Cloud Services

We use Internet-accessible software services (so-called « cloud services », also referred to as « Software as a Service ») provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users’ devices for web analysis or to remember user settings (e.g. in the case of media control).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.). Business and contractual partners.
  • Purposes of processing: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Newsletter and Electronic Communications

We send newsletters, emails, and other electronic notifications (hereinafter « newsletters ») exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users’ consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to demonstrate previously given consent. The processing of these data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of consent is confirmed. In case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

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

Contents:

Information about us, our services, promotions and offers.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing: Direct marketing (e.g. by e-mail or postal).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
  • Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing methods, procedures and services used:

  • Measurement of opening rates and click rates: The newsletters contain a so-called « web beacons », which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).
  • MailPoet: Email marketing service;
    Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://www.mailpoet.com/;
    Privacy Policy: https://automattic.com/privacy/.
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).

Web Analysis, Monitoring and Optimization

Web analytics (also referred to as « reach measurement ») is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.

Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

Additionally, users’ IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ». Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our online services by users based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online services. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online services and technical aspects of their end devices and browsers.
    In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers before forwarding traffic to Analytics servers for processing;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal Basis: Consent (Article 6 (1) (a) GDPR);
    Website: https://marketingplatform.google.com/intl/en/about/analytics/;
    Security measures: IP Masking (Pseudonymization of the IP address);
    Privacy Policy: https://policies.google.com/privacy;
    Data Processing Agreement: https://business.safety.google/adsprocessorterms/;
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland);
    Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
    Further Information:https://business.safety.google/adsservices/ (Types of processing and data processed).

Online Marketing

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

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

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

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

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Notes on revocation and objection:

We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called « opt-out »). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Cross-regional: https://optout.aboutads.info.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Affiliate Tracking; Marketing; Profiles with user-related information (Creating user profiles). Conversion tracking (Measurement of the effectiveness of marketing activities).
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ». Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Security measures: IP Masking (Pseudonymization of the IP address).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Ads and Conversion Tracking: Online marketing process for purposes of placing content and advertisements within the provider’s advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the ads, i.e. whether the users took them as a reason to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://marketingplatform.google.com;
    Privacy Policy: https://policies.google.com/privacy;
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland);
    Further Information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.

Profiles in Social Networks (Social Media)

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

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ».
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data, which is used to create « Page Insights » (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as profile details of users, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
    We have entered into a special agreement with LinkedIn Ireland (« Page Insights Joint Controller Addendum, » https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must comply with and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (particularly the right to information, deletion, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by our agreements with LinkedIn. The joint responsibility is limited to the collection of data and its transmission to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA;
    Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://www.linkedin.com;
    Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
    Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as « third-party providers »). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as « Content »).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known 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 cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Location data (Information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and usability. Provision of contractual services and fulfillment of contractual obligations.
  • Retention and deletion: Deletion in accordance with the information provided in the section « General Information on Data Retention and Deletion ». Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services;
    Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Maps: We integrate the maps of the service « Google Maps » from the provider Google. The data processed may include, in particular, IP addresses and location data of users;
    Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland;
    Legal Basis: Consent (Article 6 (1) (a) GDPR);
    Website: https://mapsplatform.google.com/;
    Privacy Policy: https://policies.google.com/privacy.
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Adequacy decision (Ireland).
  • reCAPTCHA: We integrate the « reCAPTCHA » function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called « bots »). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is based on our legitimate interest to protect our online services from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;
    Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
    Website: https://www.google.com/recaptcha/;
    Privacy Policy: https://policies.google.com/privacy;
    Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
    Opt-Out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

  • Affiliate Tracking: Custom Audiences refers to the process of determining target groups for advertising purposes, e.g. the display of advertisements. For example, a user’s interest in certain products or topics on the Internet may be used to conclude that the user is interested in advertisements for similar products or the online store in which the user viewed the products. « Lookalike Audiences » is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are typically used.
  • Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users’ consent or based on legal authorisation grounds.
  • Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
  • Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
  • Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Controller: « Controller » means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
  • Employees: As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an employer and an employee, established through an employment contract or agreement. It entails the obligation of the employer to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various stages, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.
  • Firewall: A firewall is a security system that protects a computer network or a single computer from unwanted network access.
  • Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
  • Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
  • Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
  • Personal Data: « personal data » means any information relating to an identified or identifiable natural person (« data subject »); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term « processing » covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Profiles with user-related information: The processing of « profiles with user-related information », or « profiles » for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Targeting: « Tracking » is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
  • Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.

Record of Processing Activities

Record of Processing Activities

This Verzeichnis von Verarbeitungstätigkeiten, in line with Article 30(1) of the General Data Protection Regulation (GDPR), offers a compilation of processes where personal data is processed by the controller, alongside the technical and organizational measures in accordance with Artikel 35 DSGVO.

Controller:

Dr. Behr GmbH
Herr Martin Landré
Königswinterer Str. 37a
53227 Bonn
Deutschland

Date: February 15, 2025

I. Information on the controller

CONTROLLER
___________________

Name and Address:

Dr. Behr GmbH
Herr Martin Landré
Königswinterer Str. 37a
53227 Bonn
Deutschland

URL of the legal notice (imprint):
https://www.drbehr.com/en/contact/

Email Address:
sales@drbehr.com

II. General procedural rules and information

1. Preamble

The Records of Processing Activities includes a collection of general information relevant to all the processing processes described below, as well as specific details on individual processing activities, in which personal data (hereinafter also referred to briefly as « data ») is processed. This structure aims to maintain clarity and provide precise information. The general information explains fundamental principles and guidelines applicable to all processing activities, such as adherence to data protection principles, the legal bases of data processing, and handling the rights of the individuals concerned. In the specific part of the records, detailed information on individual processing activities is listed, including the purpose of data processing, the categories of data affected, the recipients of the data, and where applicable, the transfer of data to third countries. This record serves as a central document to ensure transparency and traceability of data processing and is an essential element in fulfilling documentation obligations under the General Data Protection Regulation (GDPR).

Beschreibung:

The processing of personal data is carried out in accordance with the provisions of the General Data Protection Regulation (GDPR). This includes compliance with the principles of legality, processing in good faith, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality as set out in Article 5 GDPR. Primarily, data processing is based on the conditions for the legality of processing defined in Article 6 GDPR or on more specific permission norms. Additionally, where necessary, national data protection regulations of the country of residence or domicile of the individuals concerned are observed. More specific legal bases that apply in certain cases are explicitly listed in these Records of Processing Activities.

2.2. National data protection regulations in Germany

Beschreibung:

In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.

Beschreibung:

The controller processes personal data when data subjects are located in Switzerland, based on the Federal Act on Data Protection (« Swiss DPA »). Unlike the GDPR, the Swiss DPA does not generally require that a legal basis for the processing of personal data be named. The processing of personal data is carried out in good faith and is lawful as well as proportionate (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, personal data is collected only for a specific purpose that is recognizable to the data subject and processed only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).

2.4. Reference to the applicability of the GDPR and the Swiss DPA

Beschreibung:

This Records of Processing Activities serves both to provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, it is important to note that due to the broader spatial application and comprehensibility, the terms used by the GDPR are utilized. In particular, instead of the terms « processing » of « personal data », « predominant interest », and « particularly sensitive personal data » used in the Swiss FADP, the terms used by the GDPR, namely « processing » of « personal data », as well as « legitimate interest » and « special categories of data » are applied. However, the legal significance of these terms will continue to be determined according to the Swiss FADP within its scope of application.

III. Records of Processing Activities

1. Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as « data ») we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as « online services »).

The terms used are not gender-specific.

2. Security Precautions

In accordance with legal requirements and taking into account the state of technology, implementation costs, as well as the nature, scope, circumstances, and purposes of processing alongside the different probabilities of occurrence and the extent of threat to the rights and freedoms of natural persons, the controller implements appropriate technical and organisational measures to ensure a level of protection commensurate with the risk.

These measures specifically include ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to data as well as access to it, its input, transfer, securing availability, and its separation. Furthermore, the controller has established procedures that enable the exercise of data subject rights as well as the deletion of data and responses to threats to data. In addition, from the outset of developing or selecting hardware, software, and processes, consideration is given by the controller to protect personal data in accordance with the principles of privacy by design and privacy-friendly default settings.

2.1. Masking of the IP address

If IP addresses are processed by the controller or the service providers and technologies used by them, and a complete processing of the IP address is not necessary, the IP address will be shortened (also known as « IP masking »). In this process, the last two digits or the last part of the IP address after a dot are removed or replaced with placeholders. The shortening of the IP address serves to prevent or significantly complicate the identification of a person based on their IP address.

2.2. Securing online connections through TLS/SSL encryption technology (HTTPS)

To protect the data transmitted via the online services of the controller from unauthorised access, the controller employs TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) ensure that information transmitted between the website or app and the user’s browser, or between two servers, is encrypted. This protects the data against unauthorised access. TLS, as an advancement of SSL, provides higher security for data transmission and ensures that all transmissions comply with current security standards. The securing of a website with an SSL/TLS certificate is indicated by the presence of HTTPS in the URL, which signals secure and encrypted data transmission.

3. General Information on Data Retention and Deletion

Personal data processed by the controller will be deleted in accordance with legal requirements once the underlying consents have been revoked or no further legal bases for processing are present. This applies to cases where the original purpose of processing no longer exists or the data is no longer needed. Exceptions to this rule apply if legal obligations or special interests of the controller necessitate a longer retention or archiving of data.

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

The controller’s privacy notices provide additional information on the retention and deletion of data specifically relevant to certain processing processes.

If there are multiple details regarding the retention period or deletion deadlines for a date, the longest period always prevails.

If a period does not explicitly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred.

Data that can no longer be processed for its originally intended purpose but must be retained due to legal requirements or for other reasons will only be processed by the controller for reasons justifying their retention.

3.1. Data Retention and Deletion under German Law

The following general deadlines apply for the retention and archiving according to German law:

  • 10 Years: Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 8 Years: Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 6 Years: Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes.
  • 3 Years: Data required to consider potential warranty and compensation claims or similar contractual claims and rights, based on previous business experiences and common industry practices. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).

3.2. Data Retention and Deletion under Swiss Law

The following general retention and archiving periods apply under Swiss law:

  • 10 Years: Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
  • 10 Years: Data necessary to consider potential claims for damages or similar contractual claims and rights, unless a shorter period of five years is applicable, which is relevant in certain cases.

3.3. Review and compliance with deletion periods

Compliance with legal and internal requirements regarding the deletion of personal data is regularly reviewed. It is ensured that all personal data no longer needed or whose storage period has expired are deleted in accordance with relevant data protection regulations, or, in the case of archiving and retention obligations, processing is restricted to these purposes. These reviews of deletion processes and compliance with established deletion periods occur regularly, at least once a year. The results of the review are documented and evaluated by the person(s) responsible for the deletion review. Upon identification of deviations, corrective actions are immediately initiated, and the effectiveness of these measures is evaluated in subsequent reviews to ensure ongoing compliance.

4. Changes and Updates

The directory of processing activities will be updated as soon as changes in the processing processes require it, or when legal provisions or other compelling reasons make an adjustment necessary. Regardless of such events, a regular review of the directory takes place at least once a year to ensure that the directory always corresponds to the current processing activities and legal requirements.

5. Rights of Data Subjects

5.1. Rights of the Data Subjects under the GDPR

Data subjects are comprehensively informed about their rights in accordance with the GDPR. This information is provided either through a public privacy statement or on a case-by-case basis in a precise, transparent, understandable, and easily accessible manner. Communication is carried out in clear and simple language. The key rights include:

  • The right to object
  • The right to withdraw consent
  • The right of access
  • The right to rectification
  • The right to erasure and restriction of processing
  • The right to data portability
  • The right to lodge a complaint with a supervisory authority

5.2. Rights of the Data Subjects under the Swiss DPA

Affected individuals are comprehensively informed about their rights in accordance with the Swiss Federal Act on Data Protection. This information is provided either in a public privacy statement or, on a case-by-case basis, in a precise, transparent, understandable, and easily accessible manner. Communication is carried out in clear and simple language. The key rights include:

  • The right to access
  • The right to data portability or release
  • The right to rectification
  • The right to object
  • The right to deletion and destruction of data
  • The right to withdraw consent

6. Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

7. Business Services

Data from contractual and business partners, such as customers and prospects (collectively referred to as « contractual partners »), are processed by the controller within the framework of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example, to answer inquiries.

These data are used to fulfill the contractual obligations of the controller. This includes in particular the obligations to provide agreed services, any update obligations, and remedies for warranty and other performance disturbances. Furthermore, the data are used to protect the rights of the controller and for purposes related to administrative tasks associated with these obligations, as well as organisational management of the company.

In addition, based on legitimate interests of the controller in proper and economic business management as well as security measures to protect its contractual partners and its business operations from abuse, endangerment of their data, secrets, information, and rights (e.g., involving telecommunication-, transport- and other auxiliary services as well as subcontractors, banks, tax- and legal advisors, payment service providers or financial authorities), data is processed.

Within the scope of applicable law, data from contractual partners is only disclosed to third parties insofar as this is necessary for the aforementioned purposes or for fulfilling legal obligations. Contractual partners are informed about further forms of processing, such as for marketing purposes, within the privacy policy.

The deletion of data occurs after expiry of statutory warranty obligations and similar duties; that is generally after four years unless it is intended that data should be stored in a customer account or so long as they must be retained for legal reasons of archiving (for tax purposes usually ten years). Data disclosed by a contractual partner to the controller within a contract are deleted according to legal requirements and generally after completion of the contract.

7.1. Online Shop, Order Forms, E-commerce, and Delivery

The controller processes the data of customers to enable them to select, purchase, or order the chosen products, goods, and associated services. This also includes their payment and delivery or execution. If necessary for the execution of an order, the controller commissions service providers, especially postal, freight forwarding, and shipping companies, to ensure delivery or execution to customers. For processing payment transactions, the controller utilises the services of banks and payment service providers.

7.2. Agency Services

The controller processes the data of customers for the provision of its contractual services. These services include, among others, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, the implementation of campaigns and processes, handling, server administration, data analysis/consulting services as well as training services.

8. Business Processes and Operations

Personal data of service recipients and clients – including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes.

8.1. Contact Management and Contact Maintenance

Processes required in the context of organizing, maintaining, and securing contact information, including:

  • Setting up and maintaining a central contact database
  • Regular updates of contact information
  • Monitoring data integrity
  • Implementing data protection measures
  • Ensuring access controls

8.2. General Payment Transactions

Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows, including:

  • Creation and verification of transfers
  • Processing of direct debit transactions
  • Checking of account statements
  • Management of chargebacks
  • Account reconciliation

8.3. Accounting, Accounts Payable, Accounts Receivable

Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting, including:

  • Creation and verification of incoming and outgoing invoices
  • Monitoring and management of outstanding items
  • Execution of payment transactions
  • Handling of dunning processes
  • Account reconciliation

8.4. Financial Accounting and Taxes

Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes.

8.5. Purchasing

Processes required in the procurement of goods, raw materials, or services.

8.6. Marketing, Advertising, and Sales Promotion

Processes required in the context of marketing, advertising, and sales promotion.

9. Provision of Online Services and Web Hosting

The data of the users is processed in order to provide them with the online services of the controller. For this purpose, the IP address of the users is also processed, which is necessary to transmit the contents and functions of the controller’s online services to the user’s browser or device.

9.1. Provision of Online Offer on Rented Hosting Space

To provide online services, storage space, computing capacity, and software are used, which are rented or otherwise obtained from a corresponding server provider (also referred to as « web host »).

9.2. Collection of Access Data and Log Files

Access to the online service provided by the responsible party is logged in the form of « server log files. » These logs include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, type of browser, operating system, referrer URL, and usually IP addresses and the requesting provider. They serve security purposes, such as preventing server overload (DDoS attacks) and ensuring server stability.

Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized unless further storage is necessary for evidence purposes.

9.3. ALL-INKL

Services in the field of providing information technology infrastructure and related services.

Service Provider: ALL-INKL.COM – Neue Medien Münnich, Inhaber: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany.

Website: https://all-inkl.com/

Privacy Policy: https://all-inkl.com/datenschutzinformationen/

9.4. Sucuri

Firewall and security functions for detecting and preventing unauthorized access attempts and vulnerabilities.

Service Provider: Sucuri, LLC., parent company: GoDaddy Media Temple, Inc., 6060 Center Dr. Suite 500, Los Angeles CA 90045, USA.

Website: https://sucuri.net

Privacy Policy: https://sucuri.net/privacy

9.5. WP Rocket

Caching and loading optimization for faster website performance.

Website: https://wp-rocket.me

Privacy Policy: https://wp-rocket.me/privacy-policy

9.6. gstatic.com

Content-Delivery-Network (CDN) for delivering large media files faster and more securely.

Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Website: https://www.google.com/

Privacy Policy: https://policies.google.com/privacy

10. Use of Cookies

The controller uses cookies in accordance with legal regulations. Prior consent is obtained from users unless it is not required by law. The legal basis for processing personal data via cookies depends on user consent or the legitimate interests of the controller.

The controller implements a consent management solution, where users’ consent for the use of cookies is obtained. Users can manage and revoke their consents. The duration of consent storage is up to two years.

10.2. BorlabsCookie

Cookie consent management for obtaining, recording, managing, and revoking consents.

Website: https://borlabs.io/borlabs-cookie/

11. Contact and Inquiry Management

When initiating contact (e.g., by mail, contact form, email, or telephone), the provided information is processed to respond to inquiries and requested actions.

11.1. Contact Form

When initiating contact via the contact form, email, or other channels, the controller processes personal data to respond appropriately. This includes name, contact information, and other provided details.

11.2. Gravity Forms

Online form creation, surveys, and feedback collection.

Website: https://www.gravityforms.com

12. Artificial Intelligence (AI)

The controller uses AI for various purposes while complying with data protection regulations. AI systems process data based on legal authorization or user consent. Technical and organizational measures ensure data security and prevent misuse.

12.1. ChatGPT

AI-based natural language processing service.

12.2. DeepL

AI-based translation service for text translations and language corrections.

13. Cloud Services

Software services accessible over the Internet and executed on their providers’ servers (known as « Cloud Services », also referred to as « Software as a Service ») are used for storing and managing content, exchanging documents, and publishing information.

Personal data may be processed and stored on the providers’ servers, including basic personal data, contact details, transaction data, contracts, and related information. Cloud service providers may also process usage data and metadata for security purposes and service optimization.

13.1. Apple iCloud

Cloud storage service.

Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.

Website: https://www.apple.com

Privacy Policy: https://www.apple.com/legal/privacy/en-ww/

13.2. Google Cloud Storage

Cloud storage, cloud infrastructure services, and cloud-based application software.

Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland.

Website: https://cloud.google.com/

Privacy Policy: https://policies.google.com/privacy

Further Information: https://cloud.google.com/privacy

13.3. Microsoft Cloud Services

Cloud storage, cloud infrastructure services, and cloud-based application software.

Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland.

Website: https://microsoft.com

Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement

Security Information: https://www.microsoft.com/de-de/trustcenter

14. Newsletter and Electronic Communications

Newsletters, emails, and other electronic notifications are sent exclusively with the consent of recipients or on a legal basis. If specified at subscription, newsletter contents are tailored accordingly. Typically, only an email address is required, but additional information may be collected for personalized communication.

Email addresses that have unsubscribed may be stored for up to three years based on legitimate interests to document prior consent. Upon request, email addresses can be removed, provided that prior consent is confirmed.

14.1. Measurement of Opening Rates and Click Rates

Newsletters may contain tracking pixels to analyze opening and click behavior. Technical data such as browser details, IP address, and access time may be collected. These evaluations help adjust content and improve effectiveness.

14.2. MailPoet

Email marketing service.

Website: https://www.mailpoet.com

Privacy Policy: https://automattic.com/privacy

Service Provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland.

15. Web Analysis, Monitoring, and Optimization

Web analysis (reach measurement) is used to evaluate visitor flows and behavior. This data helps identify areas for optimization and test different versions of online services.

Unless otherwise stated, profiles are created using pseudonymous values and stored in cookies. IP masking is used for additional user protection.

15.1. Google Analytics

Google Analytics collects pseudonymous usage data to analyze visitor interactions, traffic sources, and engagement. IP addresses are masked, and only aggregate data is used for evaluation.

Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Website: Google Analytics

Privacy Policy: https://policies.google.com/privacy

Opt-Out: Google Analytics Opt-Out Plugin

16. Online Marketing

The controller processes personal data for online marketing purposes, including targeted advertising and conversion tracking. Pseudonymous user profiles are created to optimize content and advertising strategies.

16.1. Google Ads and Conversion Tracking

Google Ads displays targeted advertisements and tracks conversions (e.g., user interactions and purchases).

Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Website: https://marketingplatform.google.com

Privacy Policy: https://policies.google.com/privacy

Further Information: Google Ads Data Processing

well as information from user profiles like job function, country, industry, seniority level, company size and employment status. Privacy information regarding LinkedIn’s processing of user data can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. The controller has entered into a specific agreement with LinkedIn Ireland (« Page Insights Joint Controller Addendum », https://legal.linkedin.com/pages-joint-controller-addendum), which specifica

17. Profiles in Social Networks (Social Media)

The controller maintains online presences within social networks to communicate with users and provide information. User data may be processed outside the EU, which could affect data protection rights.

User data is typically used for market research and advertising. Usage profiles can be created based on user behavior, and cookies may track interactions. Data may also be collected across different devices if users are logged into social networks.

For more details on processing activities and opt-out options, please refer to the privacy policies of the respective social networks.

17.1. LinkedIn

The controller and LinkedIn Ireland Unlimited Company share responsibility for collecting visitor data for Page Insights statistics. This data includes interaction details, device information, IP addresses, and user profile data.

Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

Website: https://www.linkedin.com

Privacy Policy: https://www.linkedin.com/legal/privacy-policy

Opt-Out: LinkedIn Opt-Out

18. Plugins and Embedded Functions and Content

The controller integrates third-party functional and content elements, such as graphics, videos, and maps. This may require processing user IP addresses to deliver the content. Some third-party providers may also use tracking technologies like pixel tags for analytics.

If consent is obtained from users for third-party services, it serves as the legal basis for data processing. Otherwise, user data is processed based on the controller’s legitimate interests.

18.1. Google Fonts (Self-Hosted)

To ensure a user-friendly presentation, font files are hosted on our server, meaning no data is transmitted to Google.

18.2. Google Maps

The controller integrates Google Maps to display location-based content. Processed data may include IP addresses and location data.

Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland.

Website: https://mapsplatform.google.com/

Privacy Policy: https://policies.google.com/privacy

18.3. reCAPTCHA

reCAPTCHA is integrated to prevent automated spam. The tool processes various data, such as IP addresses, device information, and browsing behavior.

Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Website: https://www.google.com/recaptcha/

Privacy Policy: https://policies.google.com/privacy

19. Data Protection and Compliance

The controller ensures compliance with relevant data protection laws and regularly reviews privacy measures. Users have the right to request information, correction, or deletion of their data.