Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as "data") 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 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 offering").
The terms used are not gender-specific.
As of February 20, 2026
Table of contents
Preamble
Responsible
Overview of processing
Relevant legal bases
Security measures
International data transfers
General information on data storage and deletion
Rights of data subjects
Business services
Provision of online services and web hosting
Use of cookies
Blogs and publication media
Contact and inquiry management
Newsletters and electronic notifications
Advertising communication via email, post, fax, or telephone
Web analysis, monitoring, and optimization
Online marketing
Presence on social networks (social media)
Plug-ins and embedded functions and content
Modification and updating
Definition of terms
Responsible
David Jaime Cocovi Solberg, PalmChrom e.U.
Brigittagasse 5/2/49
1200 Vienna
Email david@palmchrom.com
Phone: +436601169366
Legal notice: www.palmchrom.com/imprint
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 data.
Content data.
Contract data.
Usage data.
Meta, communication, and procedural data.
Log data.
Categories of data subjects
Service recipients and clients.
Prospective customers.
Communication partners.
Users.
Business and contractual partners.
Purposes of processing
Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Direct marketing.
Reach measurement.
Tracking.
Office and organizational procedures.
Conversion measurement.
Target group formation.
Organizational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.
Public relations.
Sales promotion.
Business processes and business management procedures.
Relevant legal basis
Relevant legal basis under the GDPR: Below you will find an overview of the legal basis under the GDPR on 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 registered office. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.
Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (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 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) (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 Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transfer, and automated decision-making in individual cases.
Security measures
In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and responses are made to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When 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 being transmitted securely and encrypted.
General information on data storage and deletion
We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked and there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be retained for commercial or tax 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 storage and deletion of data that applies specifically to certain processing operations.
If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
Storage and deletion of data: The following general periods apply under Austrian law for the storage and archiving of personal data, insofar as this is necessary to fulfill legal obligations or to safeguard legitimate interests:
7 years Personal data processed in connection with tax-relevant business documents is retained for a period of seven years in accordance with § 132 BAO and §§ 190–212 UGB. This includes, in particular, books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents, invoices, and commercial or business letters received and sent, as well as other documents relevant to tax collection. The period begins at the end of the calendar year for which the last entry was made and is extended, if necessary, as long as the documents are relevant to pending tax proceedings.
3 years Data required for the assertion, exercise, or defense of warranty, damage compensation, or other contractual claims shall be stored for the duration of the applicable statutory limitation period. This is generally three years in accordance with Section 1489 of the Austrian Civil Code (ABGB), unless longer statutory retention obligations apply.
Start of the period at the end of the year: If a period does not expressly begin 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 which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right to revoke consent: You have the right to revoke your consent at any time.
Right to information: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with legal requirements, 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 legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.
Business services
We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures that are carried out upon request, as well as communication in connection with the respective contractual relationship.
The processing serves in particular to fulfill our main and secondary contractual obligations. This includes the provision of the agreed services, any updating and information obligations, the processing of warranty and other service disruptions, the handling of revocations, terminations of continuing obligations, rescissions, refunds, and the processing of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.
In particular, we process master data such as name, address and, if applicable, company name, contact details such as email address and telephone number, contract and service data such as contract subject matter, contract term, order or transaction number, usage and service data, payment and billing data, as well as communication content and history. Where necessary, we also process data that is disclosed or transmitted to us in the course of executing an order.
In addition, we process the data to protect our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention obligations, documentation obligations, and, where applicable, verification and accountability obligations. Processing is also carried out on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and our contractual partners from misuse, endangerment of data, secrets, and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other vicarious agents, insofar as this is necessary for the execution of the contract or to fulfill legal obligations.
Personal data will only be passed on to third parties if this is necessary for the fulfillment of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests, or for the fulfillment of legal obligations. We will provide separate information about any further processing, in particular for marketing purposes, within the scope of this privacy policy.
We will inform the contractual partners which data is required in each individual case when collecting the data, for example by marking it accordingly in online forms or in personal contact.
The data will be deleted as soon as it is no longer required for the aforementioned purposes and there are no legal retention obligations. Legal retention periods, in particular under commercial and tax law, may require longer storage. We delete data that has been transmitted in the context of a specific order after completion of the order and expiry of any retention periods, provided that there are no further legal or contractual obligations to store the data.
The legal basis for processing is Art. 6 (1) lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 (1) lit. c GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6 (1) lit. f GDPR. Insofar as the processing is based on Art. 6 (1) lit. f GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in safeguarding our entrepreneurial capacity to act.
Types of data processed: 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, term, customer category).
Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; 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 basis: Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR); legal obligation (Art. 6 (1) (c) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, processes, and services:
Project and development services: We process the data of our customers and clients (hereinafter referred to collectively as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and make available or execute or provide them.
The required information is identified as such in the context of the order, purchase order, or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for the purpose of any necessary consultations. Insofar as we obtain access to information from end customers, employees, or other persons, we process this information in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).Provision of software and platform services: We process the data of our users, registered users, and any test users (hereinafter collectively referred to as "users") in order to provide them with our contractual services and, on the basis of legitimate interests, to ensure the security of our services and to further develop them. The required information is marked as such in the context of the order, purchase order, or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for any necessary consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Technical services: We process the data of our customers and clients (hereinafter referred to uniformly as "customers") in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and make available or execute or provide them.
The required information is marked as such in the context of the order, purchase order, or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for any necessary consultations. Insofar as we obtain access to information from end customers, employees, or other persons, we process this information in accordance with the legal and contractual requirements; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Provision of online services and web hosting
We process user 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.
Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time stamps, 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 pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (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 (1) (f) GDPR).
Further information on processing procedures, processes, and services:
Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also known as a "web host"); Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data 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 prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Email dispatch and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of emails (e.g., the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
Use of cookies
The term "cookies" refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online services and to analyze visitor traffic. We use cookies in accordance with legal requirements. To do so, we obtain the consent of users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of consent and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).
Persistent cookies: Persistent cookies remain stored even after the device is closed. This allows, for example, the log-in status to be saved and preferred content to 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. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including through the privacy settings of their browser.
Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Blogs and publication media
We use blogs or similar means of online communication and publication (hereinafter referred to as "publication media"). Readers' data is only processed for the purposes of the publication media to the extent necessary for its presentation and communication between authors and readers or for security reasons. For further information, please refer to the information on the processing of visitors to our publication media in this privacy policy.
Types of data processed: 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., textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures. Organizational and administrative procedures.
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 (1) (f) GDPR).
Further information on processing procedures, processes, and services:
Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to prevent multiple votes.
The personal information provided in the context of comments and posts, any contact and website information, as well as the content information, will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
Contact and inquiry management
When contacting us (e.g., by mail, contact form, email, telephone, or social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to contact requests and any requested measures.
Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering 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(1)(f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Further information on processing procedures, processes, and services:
Contact form: When you contact us via our contact form, by email, or other means of communication, we process the personal data you provide to respond to and process your request. This usually includes information such as your name, contact details, and, if applicable, other information that you provide to us and that is necessary for proper processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal bases: fulfillment 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).
Newsletters and electronic notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or on a legal basis. If the content of the newsletter is specified during registration, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
Contents:
information about us, new products, blog entries.
Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post). Provision of contractual services and fulfillment of contractual obligations.
Legal basis: Consent (Art. 6 (1) (a) GDPR).
Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter at the end of each newsletter, or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, processes, and services:
Prerequisite for using free services: Consent to the sending of mailings may be made a prerequisite for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, we ask them to contact us.
Advertising communication via email, post, fax, or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communications at any time free of charge using the above-mentioned contact options.
After revocation or objection, we store the data necessary to prove previous authorization for contact or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
Types of data processed: 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., textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation).
Data subjects: Communication partners.
Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post); marketing. Sales promotion.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion."
Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Web analysis, monitoring, and optimization
Web analysis (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite reuse. It also enables us to identify areas that require optimization.
In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (unless otherwise specified, 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 (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing procedures, methods, and services:
Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of 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 a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, which they have accessed again, or how they have interacted with our online offering. The time and duration of use are also stored, as well as the sources of users who refer to our online offering and technical aspects of their terminal devices and browsers.
Pseudonymous user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic 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 traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/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: Data Privacy Framework (DPF), https://business.safety.google/adsprocessorterms; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, 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 purpose 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 its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used to store information about the user that is relevant for the presentation of the aforementioned content. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used, and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or using similar methods. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if the users are members of a social network, for example, whose online marketing method we use and the network links the user profiles with the aforementioned information. Please note that users can enter into additional agreements with the providers, for example, by giving their consent during registration.
We generally only receive access to summarized information about the success of our advertisements. However, we can use conversion measurements to check which of our online marketing methods have led to a conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Information on revocation and objection:
We refer you to the privacy policies of the respective providers and the options for objection (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-regional: https://optout.aboutads.info.
Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (unless otherwise specified, 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 (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods, and services:
Google Ads and conversion measurement: Online marketing procedures for the purpose of placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. In addition, we measure the conversion of the ads, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversions). 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 (Art. 6 (1) (a) GDPR), legitimate interests (Art. 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Presence on social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with 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 pose risks for users, as it could, for example, make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users' computers, in which the usage behavior and interests of users are stored. In addition, data can also be stored in the usage profiles independently of the devices used by users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, 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 and legitimate interests: Communication; feedback (e.g., collecting feedback via online form). Public relations.
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(1)(f) GDPR).
Further information on processing procedures, methods, and services:
Instagram: Social network that allows users to share photos and videos, comment on and favorite posts, send messages, and subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
Facebook pages: Profiles within the Facebook social network - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page ("fan page"). This includes, in particular, information about user behavior (e.g., content viewed or interacted with, actions performed) and device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the "Page Insights" service, which provide information about how people interact with our page and its content. This is based on an agreement with Facebook ("Information about Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transfer to Meta Platforms Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: legitimate interests (Art. 6 (1) (f) GDPR); website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), https://www.facebook.com/legal/EU_data_transfer_addendum.
LinkedIn: Social network - Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate "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. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size, and employment status. Information on 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 that LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data 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, in particular with regard to 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 (Art. 6 (1) (f) GDPR); website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), https://legal.linkedin.com/dpa. Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the users, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, but may also be linked to such information from other sources.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: 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 and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); target group formation. Marketing.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing procedures, methods, and services:
Google Fonts (obtained from Google Server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform display, and consideration of possible licensing restrictions. The IP address of the user is communicated to the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must customize the font that is generated for the respective browser type. The user agent is primarily logged for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts "Analytics" page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
Changes and updates
We ask you to regularly review the content of our privacy policy. We will amend 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 action on your part (e.g., consent) or other individual notification.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and check the information before contacting them.
Definition of terms
This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.
Inventory data: Inventory data includes essential information 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, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unique assignment and communication.
Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include text, 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 dates.
Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user's device within the websites where the marketing measures are carried out and then retrieved again on the target website. This allows us to track whether the ads we place on other websites were successful.
Meta, communication, and procedural 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, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and change history. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the people involved, timestamps, and transmission routes. Process data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify 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 features they prefer, how long they stay on certain pages, and the paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying 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 "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. cookie) or to one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.) or to predict them (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
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, monitor security, or generate performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
Tracking: Tracking refers to the ability to track user behavior across multiple online services. As a rule, information about behavior and interests is stored in cookies or on the servers of the providers of tracking technologies (known as profiling) with regard to the online offerings used. This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: The "controller" is the natural or legal person, public authority, agency, or other body that, 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 virtually any handling of data, whether it is collection, evaluation, storage, transmission, or deletion.
Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms and 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 upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving 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. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.
Target group formation: Target group formation (known as "custom audiences") refers to the process of determining target groups for advertising purposes, e.g., displaying advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. The term "lookalike audiences" (or similar target groups) is used when content that is considered suitable is displayed to users whose profiles or interests are presumed to correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.
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