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Privacy Policy En

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”), which 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, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Effective date: June 15, 2025

Table of Contents

Controller

Sect Tattoo – Owner: Anisa Bumazhenko

Lübbener Straße 23

10997 Berlin

Germany

Email address: info@secttattoo.com

Phone: +49 155 6613 5063

Overview of Processing

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

Types of Data Processed

Categories of Data Subjects

Purposes of Processing

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of 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. If more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific 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. In addition, the data protection laws of the individual federal states may apply.

Note on applicability of the GDPR and the Swiss FADP: These privacy notices serve both to provide information under the Swiss Federal Act on Data Protection (FADP) and under the General Data Protection Regulation (GDPR). For broader geographical applicability and clarity, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP such as “processing” of “personal data,” “overriding interest,” and “sensitive personal data,” the GDPR terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” are used. The legal meaning of the terms remains determined under the Swiss FADP where it applies.

Disclosure of Personal Data

In the course of our processing of personal data, it may occur that such data are transmitted to other bodies, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using third-party services or disclosure/transmission of data to other persons, bodies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy explicitly refers to data transfers to third countries), this is always done in accordance with the legal requirements.

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

This dual safeguard ensures comprehensive protection of your data: the DPF constitutes the primary protection layer, while the SCCs serve as an additional safeguard. Should changes occur regarding the DPF, the SCCs act as a reliable fallback to ensure that your data remains adequately protected even amid political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether SCCs are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Deletion

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

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

Our privacy notices contain additional information on retention and deletion of data that apply specifically to certain processing operations.

Where multiple retention or deletion periods are indicated for a datum, the longest period is decisive. If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships within which data is stored, the triggering event is the effective date of termination or other ending of the legal relationship.

Data that is no longer retained for the original purpose but due to legal requirements or other reasons will be processed exclusively for the reasons that justify its retention.

Further notes on processing operations, procedures, and services:

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

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, in particular those arising from Articles 15 to 21 GDPR:

Provision of the Online Offering and Web Hosting

We process users’ data in order to be able to provide our online services to them. 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 device.

Types of data processed: Usage data (e.g., page views and dwell time, 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, identifiers, parties 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: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures; reach measurement (e.g., access statistics, recognition of returning visitors); conversion measurement (measuring the effectiveness of marketing measures). Server monitoring and error detection.

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Provision of the online offering on rented storage: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web 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.” These may include the addresses and names of the retrieved web pages and files, date and time of retrieval, transferred data volumes, messages about successful retrieval, 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. Server log files can be used for security purposes, e.g., to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and also 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 whose further retention is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

Squarespace: Squarespace provides software as a service for creating and hosting websites; Service provider: Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.squarespace.com; Privacy Policy: https://www.squarespace.com/privacy; Data Processing Agreement: https://www.squarespace.com/dpa. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.squarespace.com/dpa).

Use of Cookies

The term “cookies” refers to functions that store information on users’ end devices and retrieve it from them. Cookies can be used for different purposes, such as to ensure the functionality, security, and convenience of online offerings, as well as to analyze visitor flows. We use cookies in accordance with legal provisions. Where necessary, we obtain users’ prior consent. If consent is not necessary, we rely on our legitimate interests. This applies if storing and retrieving information is essential to provide expressly requested content and functions. These include, for example, the storage of 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 and which cookies are used.

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

Storage duration: The following types of cookies are distinguished with respect to storage duration:

General notes on withdrawal and objection (opt-out): Users can revoke consents given at any time and can also object to processing in accordance with legal requirements, including via the privacy settings of their browser.

Types of data processed: Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identifiers, parties involved).

Data subjects: Users (e.g., website visitors, users of online services).

Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further notes on processing operations, procedures, and services:

Processing of cookie data based on consent: We use a consent management solution to obtain users’ consent to the use of cookies or to the procedures and providers listed within the consent management solution. This procedure serves to obtain, record, manage, and revoke consents, in particular regarding the use of cookies and comparable technologies used to store, retrieve, and process information on users’ end devices. Within this procedure, users’ consents for the use of cookies and the associated processing of information—including the specific processing and providers named in the consent management procedure—are obtained. Users can also manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to be able to demonstrate consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information is provided about the providers of consent management services, the following general notes apply: The storage period of consent is up to two years. 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 basis: Consent (Art. 6(1)(a) GDPR).

BorlabsCookie: Consent management solution for obtaining, recording, managing, and revoking consents, in particular for the use of cookies and similar technologies for storing, retrieving, and processing information on users’ end devices, as well as their processing; Service provider: executed on servers and/or computers under our own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, types of consent, and the time of their submission are stored server-side and in the cookie on the users’ device.

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, telephone, or via social media) and within existing user and business relationships, we process the details of the persons making the inquiry insofar as this is necessary to respond to contact inquiries and any requested measures.

Types of data processed: Inventory data (e.g., full name, residential address, contact details, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and contributions and related information such as authorship details or creation time); usage data (e.g., page views and dwell time, 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, identifiers, parties involved).

Data subjects: Communication partners.

Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further notes 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 to answer and handle the respective concern. This generally includes information such as name, contact details, and, where applicable, further information provided to us and necessary for proper handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following notes on the functionality of messengers, encryption, the use of communication metadata, and your options to object.

You can also contact us via alternative means, e.g., telephone or email. Please use the contact options provided to you or those listed within our online offering.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not visible, not even to the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure encryption of message content.

We also inform our communication partners that the providers of the messengers may not see the content but can learn that and when communication partners communicate with us and process technical information about the devices used by the communication partners and, depending on their device settings, also location information (so-called metadata).

Notes on legal bases: Where we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not request consent and they contact us on their own initiative, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure, and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting our communication partners’ needs to communicate via messenger. We also point out that we do not initially transmit the contact data provided to us to the messengers without your consent.

Withdrawal, objection, and deletion: You can withdraw consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete messages in accordance with our general deletion policies (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that any queries from communication partners have been answered, when no reference to a previous conversation is to be expected, and no statutory retention obligations preclude deletion.

Reservation to refer to other communication channels: To ensure your security, please understand that we may not be able to answer inquiries via messenger for certain reasons. This concerns situations in which, for example, contract details must be treated particularly confidentially or a response via messenger does not meet formal requirements. In such cases, we recommend that you use more appropriate communication channels.

Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and contributions and related information such as authorship details or creation time); usage data (e.g., page views and dwell time, 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, identifiers, parties involved).

Data subjects: Communication partners.

Purposes of processing: Communication. Direct marketing (e.g., by email or post).

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Consent (Art. 6(1)(a) GDPR); Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Instagram: Sending messages via the Instagram social network; 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/.

WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat function, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal. Basis for third-country transfers: Data Privacy Framework (DPF).

Cloud Services

We use software services accessible via the internet and operated on the providers’ servers (so-called “cloud services,” also referred to as “Software as a Service”) for the storage and management of content (e.g., document storage and management, exchange of documents, content, and information with specific recipients, or publication of content and information).

In this context, personal data may be processed and stored on the providers’ servers, insofar as they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. Such data may include, in particular, master and contact data of users, data on operations, contracts, other processes and their content. The providers of cloud services also process usage data and metadata, which they use for security purposes and service optimization.

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

Types of data processed: Inventory data (e.g., full name, residential address, contact details, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and contributions and related information such as authorship or creation time). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).

Data subjects: Prospective customers; communication partners; business and contractual partners. Users (e.g., website visitors, users of online services).

Purposes of processing: Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Google Cloud Services: Cloud infrastructure services and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://cloud.google.com/; Privacy policy: https://policies.google.com/privacy; Data Processing Addendum: https://cloud.google.com/terms/data-processing-addendum; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.

Google Workspace: Cloud-based application software (e.g., word processing and spreadsheets, calendar and contacts), cloud storage and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://workspace.google.com/; Privacy policy: https://policies.google.com/privacy; Data Processing Addendum: https://cloud.google.com/terms/data-processing-addendum; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further information: https://cloud.google.com/privacy.

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or on the basis of a legal permission. Where the contents of the newsletter are specified within the scope of a registration, they are decisive for users’ consent. To register for our newsletter, it is usually sufficient to provide your email address. To offer you a personalized service, we may ask for your name for a personal salutation in the newsletter or further information where necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them to be able to prove previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided 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 for this purpose alone in a blocklist (so-called “blocklist”).

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

Contents:

Types of data processed: Inventory data (e.g., full name, residential address, contact details, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); meta-, communication, and procedural data (e.g., IP addresses, timestamps, identifiers, parties involved). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).

Data subjects: Communication partners.

Purposes of processing: Direct marketing (e.g., by email or post).

Legal bases: Consent (Art. 6(1)(a) GDPR).

Opt-out option: You can cancel the receipt of our newsletter at any time, i.e., withdraw your consent or object to further receipt. A link to cancel the newsletter can be found at the end of each newsletter or you can otherwise use one of the contact options provided above, preferably email.

Further notes on processing operations, procedures, and services:

Measurement of opening and click rates: The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from their server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, your IP address, and the time of the retrieval is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates and the storage of the measurement results in users’ profiles and their further processing are based on users’ consent. A separate withdrawal of performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to. In that case, the stored profile information will be deleted; Legal basis: Consent (Art. 6(1)(a) GDPR).

Reminder emails for the ordering process: If users do not complete an ordering process, we may remind users of the ordering process by email and send them a link to continue it. This function can be useful, for example, when the purchase process could not be continued due to a browser crash, oversight, or forgetting. Dispatch is based on consent, which users can withdraw at any time; Legal basis: Consent (Art. 6(1)(a) GDPR).

Processing of appointments and communication via Tattoogenda: To manage appointment requests, appointment bookings, and to conduct customer communication (e.g., appointment confirmations, reminders, changes), we use the Tattoogenda service. The personal data you provide in the context of appointment booking and processing (e.g., name, email address, telephone number, booked services) are processed by Tattoogenda on our behalf. Processing is based on Art. 6(1)(b) GDPR (contract initiation and performance) and Art. 6(1)(f) GDPR (legitimate interest in efficient and secure appointment management and customer communication). A data processing agreement pursuant to Art. 28 GDPR exists with Tattoogenda. Further information on data protection at Tattoogenda can be found at: https://tattoogenda.com/privacy-policy; Service provider: Tattoogenda BV, Steenweg op Gierle 234/3, 2300 Turnhout, Belgium (EU); Website: https://tattoogenda.com/. Privacy policy: https://tattoogenda.com/privacy-policy.

Promotional Communication via Email, Mail, Fax or Telephone

We process personal data for the purposes of promotional communication, which may take place via various channels such as email, telephone, mail, or fax in accordance with legal requirements.

Recipients have the right to withdraw consent given at any time or to object to promotional communication at any time.

After withdrawal or objection, we store the data necessary to prove the prior authorization for contacting or sending for up to three years after the end of the year of withdrawal 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 withdrawal or objection of users, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, name).

Types of data processed: Inventory data (e.g., full name, residential address, contact details, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., textual or visual messages and contributions and related information such as authorship details or creation time).

Data subjects: Communication partners.

Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

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 provide information about us.

We point out that user data may be processed outside the European Union. This may pose risks for users because, for example, enforcement of users’ rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests. These profiles may in turn be used to display advertisements within and outside the networks that presumably correspond to users’ interests. Cookies are generally stored on users’ computers for this purpose, in which users’ usage behavior and interests are stored. In the profiles, data may also be stored independently of the devices used by users (especially if they are members of the respective platforms and 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 information requests and the exercise of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the latter have access to user data and can take direct action and provide information. If you still need help, you can contact us.

Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and contributions and related information such as authorship details or creation time); usage data (e.g., page views and dwell time, 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, identifiers, parties involved).

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing: Communication; feedback (e.g., collecting feedback via online form). Public relations.

Retention and deletion: Deletion as indicated in the section “General Information on Data Storage and Deletion”.

Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further notes on processing operations, procedures, and services:

Instagram: Social network enabling sharing photos and videos, commenting and favoriting posts, messaging, subscribing 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 social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “Fanpage”). This data includes information about the types of content that users view or interact with or actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights,” to page operators to provide them with insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular what security measures Facebook must observe and in which Facebook undertakes to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Users’ rights (in particular to access, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company 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), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).

TikTok: Social network enabling sharing photos and videos, commenting and favoriting posts, messaging, subscribing to accounts; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy. Basis for third-country transfers: Standard Contractual Clauses (https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms).

Plug-ins and Embedded Functions and Content

We integrate function 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 include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as “content”).

Integration always requires that the third-party providers of this content process users’ IP addresses, since they could not send the content to users’ browsers without an IP address. The IP address is therefore necessary for the display of this content or 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 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 users’ devices and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, as well as other information about the use of our online offering, and may also be combined with such information from other sources.

Notes 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, 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 also 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 dwell time, 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, identifiers, parties involved). Location data (information on the geographic position of a device or person).

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing: Provision of our online offering and user-friendliness; marketing. Profiles with user-related information (creating user profiles).

Retention and deletion: Deletion as indicated 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 may be stored on users’ devices for a period of two years).

Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Google Fonts (retrieval from the Google server): Retrieval of fonts (and icons) for the purpose of technically secure, maintenance-free and efficient use of fonts and icons with regard to up-to-dateness and loading times, their uniform display and consideration of possible license restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be provided 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 the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CSS. 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 that describes the browser and operating system versions of website visitors, as well as the referrer URL (i.e., the webpage on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of the 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 wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. In the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging 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 referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to its own information, Google does not use any 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.

Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Instagram plug-ins and content: Instagram plug-ins and content – These can include content such as images, videos, or texts and buttons with which users can share content from this online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of “event data” that Facebook collects using Instagram functions (e.g., embedding functions for content) that are executed on our online offering, or receives in the context of a transmission for the following purposes: a) display of content and advertising information that correspond to users’ presumed interests; b) delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improvement of ad delivery and personalization of functions and content (e.g., improvement of recognition of which content or advertising information presumably corresponds to users’ interests). We have concluded a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook undertakes to fulfill data subjects’ rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., contain no information about individual users and are anonymous to us), such processing does not take place under joint responsibility, but on the basis of a processing contract (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum). Users’ rights (in particular to access, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; 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/.

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in our data processing make this necessary. We will inform you when the changes require an action of cooperation on your part (e.g., consent) or another individual notification.

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

Definitions

In this section, you will receive an overview of the terms used in this privacy policy. Where terms are defined by law, their legal definitions apply. The following explanations primarily serve to aid understanding.

Inventory data: Inventory data includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic details 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, institutions, or systems by enabling unambiguous 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 may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.

Contact data: Contact data are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication means such as social media handles and instant messaging identifiers.

Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a process used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. In this way, we can track whether the advertisements 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. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. They may include information on file size, creation date, the author of a document, and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the parties involved, timestamps, and transmission paths. Procedural data describe the processes and sequences within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.

Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages, and which paths they take through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are 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” is 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, includes any type of automated processing of personal data that consists in using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, different information regarding demographics, behavior and interests, such as interaction with websites and their content). Cookies and web beacons are often used for profiling purposes.

Log data: Log data is information about events or activities that has been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to generate performance reports.

Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as content on websites. With the help of reach analysis, operators of online offerings can recognize, for example, at which time users visit their websites and which content interests them. This allows them to better adapt the content of the websites to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.

Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online offering and use the processed data to optimize our online offering technically. Performance, load, and comparable technical values are processed, which provide information about the stability and any anomalies of our online offering. In the event of errors and anomalies, individual requests by users of our online offering are recorded in order to identify and correct sources of problems.

Location data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, a WLAN, or similar technical means and functions of location determination. Location data indicates the geographically determinable position on earth at which the respective device is located. Location data can be used to display map functions or other information dependent on a location.

Controller: The “controller” is the natural or legal person, authority, institution 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 practically any handling of data, whether collecting, evaluating, storing, transmitting or erasing.

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