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Data protection

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of 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 offer”).

The terms used are not gender-specific.

Status: July 3, 2024

Legal text by Dr. Schwenke - please click for further information.

Table of contents

Person responsible

Matthias Luthardt
Stubbenkammerstr.8
10437 Berlin

Persons authorized to represent the company: Angela Maria González Ponce de Léon

E-mail address: matthias@kinomat.net

Imprint: https://kinomat.net/impressum/

Overview of processing

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

Types of data processed

  • Inventory data.
  • Payment data.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Protocol data.
  • Creditworthiness data.

Special categories of data

  • Health data.

Categories of affected persons

  • Beneficiary and client.
  • Employees.
  • Interested parties.
  • Communication partner.
  • Users.
  • Business and contractual partners.
  • Third parties.
  • Customers.

Purposes of the processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Safety measures.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Provision of our online services and user-friendliness.
  • Assessment of creditworthiness and credit standing.
  • Information technology infrastructure.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and business management procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the 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.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection 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 the access, input, transfer, safeguarding of availability and its separation. We have also set up procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is shortened (also known as “IP masking”). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it significantly more difficult to identify a person by their IP address.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use 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 transmitted between the website or app and the user’s browser (or between two servers), which protects the data from unauthorized access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by 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 transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the organization: Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to it. If the data is passed on for administrative purposes, it is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This concerns cases in which the original purpose of processing no longer applies or the data is no longer required. There are exceptions to this rule if legal obligations or special interests require longer storage or archiving of the data.

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

Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more than one indication of the retention period or deletion period for a date, the longest period is always decisive.

If a period does not expressly start on a specific date and is at least one year, it automatically starts 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.

We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.

Further information on processing operations, procedures and services:

  • Retention and deletion of data: The following general time limits apply to retention and archiving under German law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
    • 6 years – Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are of significance for taxation, e.g. Hourly wage slips, company accounting sheets, calculation documents, price markings, but also payroll accounting documents, insofar as they are not already accounting documents and cash register strips (§ 147 para. 3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
    • 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of the data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) GDPR. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you 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 the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
  • Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships and associated measures and with regard to communication with the contractual partners (or pre-contractual), for example to respond to inquiries.

We use this data to fulfill our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests both in proper and efficient business management and in security measures to protect our contractual partners and our business operations from misuse, threats to 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 pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data that has been disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

  • Processed data types: Inventory data (e.g. 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 telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Special categories of personal data: Health data.
  • Persons concerned: Beneficiaries and clients; interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Online store, order forms, e-commerce and delivery: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Personal training: Personal training procedures include the acquisition and management of client data, including the collection, storage and use of contact information, training preferences and individual goals. At the beginning of a training relationship, extensive health information such as allergies, previous illnesses, medications and injury history is collected in order to develop safe and effective training programs. The creation of customized training plans is based on the analysis of the client’s personal fitness data, goals and progress measurements. Personal data is used to coordinate training dates and locations in order to ensure smooth organization and communication. Conducting regular fitness assessments and performance tests requires the collection and evaluation of individual performance data in order to monitor progress and adapt training plans. For the provision of supplementary services, such as nutritional advice or lifestyle coaching, further personal data is processed in order to offer holistic support. Regular feedback discussions and evaluations, which may also contain personal data, are carried out to continuously improve the quality of training and customer satisfaction. Communication with clients takes place via various channels, such as email, telephone or messenger services, whereby personal data is exchanged in order to arrange appointments, answer questions and provide support; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Event management: We process the data of the participants of the events, functions and similar activities offered or organized by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and make use of the services or promotions associated with participation.

    If we process health-related data, religious, political or other special categories of data in this context, this is done in the context of disclosure (e.g. for themed events or for health care, security or with the consent of the data subjects).

    The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business processes and procedures

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

The data collected is used to fulfill contractual obligations and to efficiently design operational processes. This includes processing business transactions, managing customer relationships, optimizing sales strategies and ensuring internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.

Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.

  • Processed data types: Inventory data (e.g. 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 telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content). contract object, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behavior).
  • Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; customers; third parties; users (e.g. website visitors, users of online services). Employees (e.g. salaried employees, applicants, temporary staff and other employees).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures; business processes and business management procedures; security measures; provision of our online offer and user-friendliness; communication; marketing; sales promotion; public relations; assessment of creditworthiness and credit standing; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further information on processing operations, procedures and services:

  • Contact management and maintenance: Procedures required to organize, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Customer account: Customers can create an account within our online offering (e.g. customer or user account, “customer account” for short). If it is necessary to register a customer account, customers will be informed of this and of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is stored for purposes other than provision in the customer account or must be stored for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer’s responsibility to back up their data when terminating the customer account; legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. creating and checking incoming and outgoing invoices, monitoring and managing open items, carrying out payment transactions, processing dunning procedures, reconciling accounts in the context of receivables and payables, accounts payable and accounts receivable); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of taxes); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Payment procedure

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and the data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

  • Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Affected persons: Service recipients and clients; business and contractual partners. Interested parties.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and business management procedures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
  • Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
  • PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
  • Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
  • Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third country transfers: Adequacy decision (UK).

Provision of the online offer and web hosting

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

  • Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offer is recorded in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) .Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore assume no responsibility for the transmission path of the e-mails between the sender and receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Hetzner: services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to save the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, permission is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to them and contains the information on the respective use of cookies.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask for their consent. If users accept, the legal basis for the processing of their data is their declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

  • Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers named in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read and process information on users’ end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Cookie opt-out: In the footer of our website you will find a link that you can use to change your cookie settings and revoke your consent; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Complianz: Consent management: Procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing; Service provider: Execution on servers and/or computers under its own responsibility under data protection law; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/. Further information: An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user’s device.

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (user name, password and an e-mail address).

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

  • Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Deletion after termination.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Registration with pseudonyms: Users may use pseudonyms as usernames instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • User profiles are not public: User profiles are not visible or accessible to the public.
  • Two-factor authentication: Two-factor authentication provides an extra layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, you must perform another authentication measure in addition to your password (e.g. enter a code sent to a mobile device). We will inform you about the procedure we use; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to a legal permission, obligation or consent of the users; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Contact and request management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

  • Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Affected persons: Communication partner.
  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes details such as name, contact information and, if applicable, other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

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

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are defined as persons who are in an employment relationship, whether as employees, salaried employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It includes the employer’s obligation to pay remuneration to the employee while the employee performs his work. The employment relationship comprises various phases, including the establishment phase, in which the employment contract is concluded, the performance phase, in which the employee carries out his or her work activities, and the termination phase, when the employment relationship ends, whether by termination, severance agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
  • Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
  • Content data: Content data includes information that is generated in the course of creating, editing and publishing content of all kinds. This category of data can include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication data
  • Contact details: Contact data is essential information that enables communication with people or organizations. They include telephone numbers, postal addresses and e-mail addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Metadata, communication data and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. They can contain information on the file size, the creation date, the author of a document and the change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they use to navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in recognizing trends, preferences and potential problem areas within digital offerings
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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 (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
  • Controller: The “controller” is 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.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
  • Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. They contain details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also contain information about the payment status, chargebacks, authorizations and fees.