Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to simply as "data") that we process, for what purposes and to what extent. This 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 the "online offer").

The terms used are not gender-specific.

Last updated: 5 July 2026

Controller

Armel Tchatchou
Sitezack
Eichwiesenstrasse 9,
64285 Darmstadt

Email address: info@sitezack.com

Legal notice (Impressum): https://codeage.net/en/impressum

Overview of processing operations

The following overview summarises 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.
Interested parties.
Communication partners.
Users.
Business and contractual partners.
Education and course participants.

Purposes of processing

Provision of contractual services and fulfilment of contractual obligations.
Communication.
Security measures.
Reach measurement.
Office and organisational procedures.
Organisational and administrative procedures.
Feedback.
Profiles with user-related information.
Registration procedures.
Provision of our online offer and user-friendliness.
Information technology infrastructure.
Business processes and 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 requirements may apply in your or our country of residence or domicile. Should more specific legal bases also be relevant in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6(1) sentence 1 point (a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (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) sentence 1 point (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6(1) sentence 1 point (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 the protection of personal data.

National data protection provisions in Germany: In addition to the data protection provisions of the GDPR, national data protection provisions apply in Germany. These include in particular the Act on Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special provisions on the right of access, 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.

Note on the applicability of the GDPR and the Swiss FADP: These data protection notices serve to provide information both under the Swiss Federal Act on Data Protection (FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial scope and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss FADP, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are employed. However, the legal meaning of the terms continues to be determined under the Swiss FADP within the scope of the FADP's applicability.

Security measures

In accordance with legal requirements and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These 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, disclosure, availability and separation relating to it. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data and responses to threats to data. We also 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 by design and by default.

Shortening of the IP address: Where IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits, or the last part of the IP address after a dot, are removed or replaced by a placeholder. The shortening of the IP address is intended to prevent or significantly hinder the identification of a person by means of their IP address.

Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted via our online services from unauthorised access, we rely on 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 transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised 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 signalled by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and in encrypted form.

Transmission of personal data

In the course of our processing of personal data, it may happen that such data is transmitted to or disclosed to other entities, companies, legally independent organisational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content embedded in a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International data transfers

Data processing in third countries: Where we transmit data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or where this occurs in the context of using third-party services or the disclosure or transmission of data to other persons, entities or companies (which is recognisable from the postal address of the respective provider or where the privacy policy expressly refers to the transfer of data to third countries), this always takes place in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission of 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the DPF framework, the standard contractual clauses take effect as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. You can find further information on the DPF and a list of certified companies on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate security measures apply, in particular standard contractual clauses, express consents or legally required transmissions. You can find information on third-country transfers and applicable adequacy decisions in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

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

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

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

Where there are multiple indications regarding the retention period or deletion deadlines of a piece of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but due to legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organisational documents required for their understanding (§ 147(1) no. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) no. 1 in conjunction with (4) HGB).
8 years - Accounting vouchers, such as invoices and cost receipts (§ 147(1) no. 4 and 4a in conjunction with (3) sentence 1 AO and § 257(1) no. 4 in conjunction with (4) HGB).
6 years - Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents insofar as they are of importance for taxation, e.g. hourly wage slips, operating accounting sheets, calculation documents, price markings, but also payroll accounting documents insofar as they are not already accounting vouchers, and cash register receipts (§ 147(1) no. 2, 3, 5 in conjunction with (3) AO, § 257(1) no. 2 and 3 in conjunction with (4) HGB).
3 years - Data required to take into account potential warranty and damages claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and customary industry practices, is stored for the duration of the standard statutory limitation period of three years (§§ 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin 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 course of which data is stored, the event triggering the period is the point at which the termination or other end 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 Art. 15 to 21 GDPR:

Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw consent given at any time.
Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to request that data concerning you be erased without delay, or alternatively, in accordance with the legal requirements, to request a restriction of 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 accordance with the legal requirements, in a structured, commonly used and machine-readable format, or to request its transmission to another controller.
Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or 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 the personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers and other cooperation partners (collectively "contractual partners"), for the purposes of initiating, performing and settling contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken on request as well as communication in connection with the respective contractual relationship.

The processing serves in particular the fulfilment of our main and ancillary contractual obligations. This includes the provision of the agreed services, any updating and information obligations, the handling of warranty and other performance defects, the processing of withdrawals, terminations of continuing obligations, reversals, refunds as well as the processing of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.

In particular, master data such as name, address and, where applicable, company, contact data such as email address and telephone number, contract and performance data such as subject matter of the contract, contract term, order or transaction number, usage and performance data, payment and billing data as well as communication content and histories are processed. Where necessary, we also process data disclosed or transmitted to us in the course of performing an order.

In addition, we process the data to safeguard our rights and to fulfil legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations as well as, where applicable, obligations to provide evidence and render accounts. Processing also takes place on the basis of our legitimate interests in the proper management of business, internal administration, risk management and IT security as well as the protection of our business operations and our contractual partners from misuse, endangerment of data, secrets and other legal assets. 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 advisers or other vicarious agents, insofar as this is necessary for the performance of the contract or for the fulfilment of legal obligations.

Personal data is disclosed to third parties only to the extent that this is necessary for the performance of the contract, the implementation of pre-contractual measures, the safeguarding of legitimate interests or the fulfilment of legal obligations. We inform you separately, within the scope of this privacy policy, about any processing that goes beyond this, in particular for marketing purposes.

We inform the contractual partners which data is required in individual cases in the course of data collection, e.g. in online forms by means of appropriate marking or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no legal retention obligations preclude this. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the course of a specific order is deleted by us after completion of the order and expiry of any retention periods, provided that no further legal or contractual obligations to store the data exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for the implementation of pre-contractual measures and the fulfilment of the respective contractual relationship as well as Art. 6(1)(c) GDPR for the fulfilment of legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Insofar as the processing is based on Art. 6(1)(f) GDPR, it takes place to safeguard our legitimate interests in the proper and efficient organisation of business, the internal administration and documentation of business transactions, the assertion and defence of legal claims, ensuring IT and data security, preventing misuse and fraud as well as the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations as well as in safeguarding our entrepreneurial capacity to act.

Types of data processed: Inventory data (e.g. full name, home 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); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Data subjects: Service recipients and clients; Interested parties; Business and contractual partners. Education and course participants.
Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Security measures; Communication; Office and organisational procedures; Organisational and administrative procedures. Business processes and management procedures.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR); Legal obligation (Art. 6(1) sentence 1 point (c) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Online shop, order forms, e-commerce and performance of services: We process the data of our customers in order to enable them to select, purchase or order the chosen products, goods and associated services, as well as their payment and provision, delivery or execution. Insofar as necessary for the execution of an order, we use service providers, in particular postal, freight and shipping companies, to carry out the delivery or execution to our customers. For the handling of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the course of the order or comparable acquisition process and comprises the information required for delivery or provision and billing as well as contact information in order to be able to make any enquiries; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).
Education and training services: We process the data of the participants in our education and training offers (uniformly referred to as "trainees") in order to be able to provide our training services to them. The data processed in this context, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship. The forms of processing also include performance assessment and the evaluation of our services as well as those of the teachers. In the course of our activity, we may also process special categories of data, here in particular information on the health of the trainees as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. For this purpose, we obtain, where necessary, the express consent of the trainees and otherwise only process the special categories of data where this is necessary for the provision of the training services, for purposes of health care, social protection or the protection of the vital interests of the trainees; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).

Payment procedures

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use, in addition to banks and credit institutions, further service providers for this purpose (collectively "payment service providers"). Payment transactions are carried out, in accordance with the state of the art, exclusively via encrypted connections, so that the data entered is protected from unauthorised access during transmission.

The data processed by the payment service providers includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as the contract-, sum- and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. That is, we do not receive any account- or credit card-related information, but only information confirming or denying the payment. In some cases, the data is transmitted by the payment service providers to credit agencies. The purpose of this transmission is identity and creditworthiness checks. In this regard, we refer to the terms and conditions and the data protection notices of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of withdrawal, access and other data subject rights.

Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Data subjects: Service recipients and clients; Business and contractual partners. Interested parties.
Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations. Business processes and management procedures.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Provision of the online offer and web hosting

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

Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: 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.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (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 bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).
Collection of access data and log files: Access to our online offer is logged 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, 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, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Content delivery network: We use a "content delivery network" (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (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 bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner. Data processing agreement: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner.

Use of cookies

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies can also be used for various purposes, e.g. for the functionality, security and comfort of online offers as well as for the creation of analyses of visitor flows. We use cookies in accordance with the legal provisions. To this end, we obtain the users' consent in advance where required. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to be able to provide expressly requested content and functions. These include, for example, the storage of settings as well as ensuring the functionality and security of our online offer. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used.

Notes on data protection legal bases: Whether we process personal data using cookies depends on consent. Where consent exists, 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, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the device is closed. Thus, for example, the login status can be stored and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Insofar as we do not provide users with explicit information on the type and storage period of cookies (e.g. in the course of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General notes on withdrawal and objection (opt-out): Users can withdraw the consent they have given at any time and, in addition, object to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

Types of data processed: Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Consent (Art. 6(1) sentence 1 point (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 by means of which the consent of users to the use of cookies or to the procedures and providers mentioned in the context of the consent management solution is obtained. This procedure serves to obtain, log, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' devices. In the context of this procedure, the users' consents to the use of cookies and the associated processing of information, including the specific processing operations and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and withdraw their consents. The consent declarations are stored in order to avoid having to request them again and to be able to provide evidence of consent in accordance with the legal requirements. 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. Insofar as no specific information on the providers of consent management services is available, the following general notes apply: the storage period of the consent is up to two years. In this process, a pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of consent (e.g. relevant categories of cookies and/or service providers) as well as information about the browser, the system and the device used; Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR).

Registration, login and user account

Users can create a user account. In the course of registration, the required mandatory information is communicated to the users and processed for the purpose of providing the user account on the basis of the fulfilment of contractual obligations. The data processed includes in particular the login information (username, password and an email address).

In the context of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. Storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is not, as a rule, disclosed to third parties, unless this is necessary to pursue our claims or there is a legal obligation to do so.

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

Types of data processed: Inventory data (e.g. full name, home 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 contributions as well as the information concerning them, e.g. information on authorship or time of creation); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files concerning logins or the retrieval of data or access times).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Security measures; Organisational and administrative procedures. Provision of our online offer and user-friendliness.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Deletion after termination.
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Users' profiles are not public: The profiles of the users are not publicly visible or accessible.
Deletion of data after termination: When users have terminated their user account, their data relating to the user account is deleted, subject to a legal permission, obligation or consent of the users; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).
No obligation to retain data: It is incumbent on the users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all of the user's data stored during the term of the contract; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).

Single sign-on login

"Single sign-on" or "single sign-on login or authentication" refers to procedures that allow users to log in using a user account with a provider of single sign-on procedures (e.g. a social network), including with our online offer. The prerequisite for single sign-on authentication is that the users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already logged in with the single sign-on provider and confirm the single sign-on login via a button.

Authentication takes place directly with the respective single sign-on provider. In the course of such authentication, we receive a user ID with the information that the user is logged in under this user ID with the respective single sign-on provider, and an ID that cannot be used by us for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected in the course of authentication and, in addition, on which data the users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the users' choice, this can be various data, as a rule the email address and the username. The password entered in the course of the single sign-on procedure with the single sign-on provider is neither visible to us nor stored by us.

Users are asked to note that the information stored with us can be automatically synchronised with their user account with the single sign-on provider, although this is not always possible or actually happens. If, for example, the users' email addresses change, they must change these manually in their user account with us.

We can use the single sign-on login, insofar as agreed with the users, in the course of or before the performance of the contract, insofar as the users have been asked to do so, process it in the context of a consent and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure login system.

Should users at some point decide that they no longer wish to use the link between their user account with the single sign-on provider for the single sign-on procedure, they must remove this connection within their user account with the single sign-on provider. If users wish to delete their data with us, they must terminate their registration with us.

Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; Security measures; Registration procedures. Provision of our online offer and user-friendliness.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Deletion after termination.
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Google single sign-on: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR); Website: https://www.google.com/; Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Objection option (opt-out): Settings for the display of advertisements: https://myadcenter.google.com/.

Contact and enquiry management

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

Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, e.g. information on authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR).

Further information on processing operations, procedures and services:

Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us in order to respond to and process the respective request. This usually includes information such as name, contact information and, where applicable, further information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of the contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 point (b) GDPR), Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Web analytics, monitoring and optimisation

Web analytics (also referred to as "reach measurement") serves to evaluate the visitor flows of our online offer and can include behaviour, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used, or encourage reuse. Likewise, it is possible for us to understand which areas require optimisation.

In addition to web analytics, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

Unless otherwise stated below, profiles, i.e. data combined into a usage process, can be created for these purposes and information can be stored in a browser or device and then read out. 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. Insofar as users have consented to the collection of their location data, towards us or towards the providers of the services we use, the processing of location data is also possible.

In addition, the users' IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. That is, we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on legal bases: Insofar as we ask users for their consent to the use of the third-party providers, the legal basis for the data processing is consent. Otherwise, the users' 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 draw your attention to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, 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).
Retention 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 stated, cookies and similar storage methods can be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymisation of the IP address).
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users takes place with the help of a so-called "digital fingerprint", which is stored anonymised and changed every 24 hours; with the "digital fingerprint", user movements within our online offer are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected in the context of using Matomo is only processed by us and not shared with third parties; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR); Website: https://matomo.org/. Security measures: IP masking (pseudonymisation of the IP address).

Plug-ins and embedded functions and content

We embed functional and content elements in our online offer 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 embedding always requires that the third-party providers of this content process the users' IP address, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functions. We endeavour to use only such 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 referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit as well as further information on the use of our online offer, but also be combined with such information from other sources.

Notes on legal bases: Insofar as we ask users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the users' 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 draw your attention to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, 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 offer and user-friendliness.
Retention 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 stated, cookies and similar storage methods can be stored on users' devices for a period of two years).
Legal bases: Consent (Art. 6(1) sentence 1 point (a) GDPR). Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Further information on processing operations, procedures and services:

Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly display of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6(1) sentence 1 point (f) GDPR).

Amendment and updating

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as the 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.

Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before making contact.

Supervisory authority responsible for us:

The Hessian Commissioner for Data Protection and Freedom of Information (Der Hessische Beauftragte für Datenschutz und Informationsfreiheit)
Postfach 3163
65021 Wiesbaden

Definitions of terms

In this section you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data can include, among other things, 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 persons and services, facilities or systems by enabling unambiguous assignment and communication.
Content data: Content data comprises information generated in the course of the creation, editing and publication of content of all kinds. This category of data can include texts, images, videos, audio files and other multimedia content that is 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 persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about how data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and modification histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify processes.
Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data comprises 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 navigate through an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible problem areas within digital offers.
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 factors specific to the physical, physiological, genetic, mental, 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, comprises any type of automated processing of personal data consisting of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this can include different information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or place of residence). Cookies and web beacons are frequently 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 analyse system problems, for security monitoring or to create performance reports.
Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as content of web pages. With the help of reach analysis, operators of online offers can, for example, recognise at what time users visit their web pages and which content they are interested in. This enables them, for example, to better adapt the content of the web pages to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
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" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collection, evaluation, storage, transmission or deletion.
Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and comprises both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include start and end dates of the contract, the nature of the agreed services or products, price agreements, payment terms, rights of termination, extension options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is decisive for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of decisive importance 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 data, verification numbers and billing information. Payment data can also contain information about the payment status, chargebacks, authorisations and fees.

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Privacy Policy

Preamble

Table of contents

Controller

Overview of processing operations

Types of data processed

Categories of data subjects

Purposes of processing

Relevant legal bases

Security measures

Transmission of personal data

International data transfers

General information on data storage and deletion

Rights of data subjects

Business services

Payment procedures

Provision of the online offer and web hosting

Use of cookies

Registration, login and user account

Single sign-on login

Contact and enquiry management

Web analytics, monitoring and optimisation

Plug-ins and embedded functions and content

Amendment and updating

Definitions of terms

🧠Quick recap

PRO lesson

Quick recap