
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") 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 connection with the provision of our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as the "online offering").
The terms used are not gender-specific.
Last updated: March 24, 2026
Controller
PLAN D GmbH
Weinmeisterstraße 12
10178 Berlin
Authorized representatives: Dirk Schmachtenberg, Sebastian Bluhm
Email address: info@plan-d.com
Legal notice: Imprint
Data Protection Officer Contact
Sebastian Dramburg
Attorney at Law & Partner
DSK DRAMBURG Rechtsanwälte
Schlüterstraße 29, 10629 Berlin
sd@dskdramburg.de
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of Data Processed
- Master data.
- Employee data.
- Payment data.
- Location data.
- Contact data.
- Content data.
- Contractual data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
- Recipients of services and clients.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Business and contractual partners.
- Third parties.
- Whistleblowers.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Audience targeting.
- Organizational and administrative procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Registration procedures.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Whistleblower protection.
- Public relations.
- Sales promotion.
- Business processes and operational procedures.
Applicable Legal Bases
Applicable legal bases under the GDPR: The following provides 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 country or ours. If more specific legal bases are applicable in individual cases, we will inform you of these in this privacy policy.
- Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Act on Protection against 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, transmission, and automated individual decision-making including profiling. Furthermore, the data protection laws of the individual German federal states (Länder) may also apply.
Security Measures
We implement appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include in particular securing the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, disclosure, security of availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data security threats. We also take the protection of personal data into account when developing or selecting hardware, software, and processes in accordance with the principle of privacy by design and privacy by default.
Securing online connections via TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and more secure version of SSL, ensures that all data transfers comply with the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and in encrypted form.
Transmission of Personal Data
In the course of our processing of personal data, it may occur that data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of 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 if this occurs in the context of using third-party services or disclosing or transferring data to other persons, entities, or companies (which is evident from the postal address of the respective provider or if the privacy policy expressly refers to data transfers to third countries), this is always carried out in accordance with the legal requirements.
For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 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 an additional layer of security. Should any changes arise within the framework of the DPF, the Standard Contractual Clauses will serve as a reliable fallback. This ensures that your data remains adequately protected even in the event of potential political or legal changes.
For the individual service providers, we will inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information about the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission at: 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 personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or no further legal bases for the processing exist. This applies to cases where the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if statutory obligations or special interests require longer retention or archiving of data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the assertion or enforcement of legal claims or for the protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.
If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.
Retention and deletion of data: The following general deadlines apply for 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 operating instructions and other organizational 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 expense 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: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation purposes, e.g., hourly wage records, operating account sheets, costing documents, price tags, but also payroll documents insofar as they are not already accounting vouchers, and cash register tapes (§ 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 damage claims or similar contractual claims and rights and to process related inquiries, based on past business experience and customary industry practices, are retained for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Deadline starting at end of year: If a deadline does not begin expressly on a specific date and is at least one year in duration, it automatically starts at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the time at which the termination or other end of the legal relationship becomes effective.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If 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 insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consents granted at any time.
- Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to receive information about such data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right, in accordance with legal requirements, to request the completion of 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 legal requirements, to request that data concerning you be deleted without undue delay, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.
- Right to lodge a complaint with 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 relating to you infringes the provisions of the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, prospects, suppliers, and other cooperation partners (collectively referred to as "contractual partners"), for the purpose of establishing, executing, and processing contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken at the request of the respective persons, as well as communication in connection with the respective contractual relationship.
The processing serves in particular the fulfillment of our primary and secondary contractual obligations. These include the provision of agreed services, any update and notification obligations, the handling of warranty claims and other service disruptions, the processing of withdrawals, terminations of long-term contracts, reversals, refunds, and the handling of other contract-related declarations and inquiries. Both one-time contracts and ongoing contractual relationships are covered.
Processed data includes in particular master data such as name, address, and where applicable company name, contact data such as email address and telephone number, contract and service data such as subject matter, contract term, order or process number, usage and service data, payment and billing data, as well as communication content and history. Where necessary, we also process data that is disclosed or transmitted to us in the course of executing a contract.
In addition, we process the data to protect our rights and to fulfill legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations, and where applicable proof and accountability obligations. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and contractual partners from misuse, data breaches, and other threats. This may also include the engagement of external service providers such as IT and telecommunications providers, transportation and logistics companies, payment service providers, banks, tax advisors and legal advisors, or other vicarious agents, to the extent required for contract execution or the fulfillment of legal obligations.
Personal data is disclosed to third parties only to the extent necessary for the performance of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests, or for the fulfillment of legal obligations. We provide separate information on any further processing, in particular for marketing purposes, within this privacy policy.
The data required in each individual case is communicated to contractual partners in the course of data collection, for example in online forms through appropriate labeling or in personal contact.
Data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific contract is deleted after completion of the contract and expiration of any applicable retention periods, unless further statutory or contractual retention obligations require storage.
The legal basis for processing is Art. 6(1)(b) GDPR for the implementation of pre-contractual measures and performance of the respective contractual relationship, and Art. 6(1)(c) GDPR for compliance with legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Insofar as processing is based on Art. 6(1)(f) GDPR, it is carried out to protect our legitimate interests in proper and efficient business organization, internal administration and documentation of business transactions, the assertion and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the financial management and further development of our business operations.
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers). Contractual data (e.g., subject matter of contract, term, customer category).
- Data subjects: Recipients of services and clients; Prospective customers. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and operational 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 inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Agency services: We process the data of our clients in the context of our contractual services, which may include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
- Project and development services: We process the data of our customers and clients to enable them to select, procure, or commission the chosen services or works, as well as related activities, and to make payment for and receive delivery or performance of such services. The required information is indicated as such within the context of the order or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information enabling us to make any necessary follow-up inquiries. Insofar as we gain access to information of end customers, employees, or other persons, we process this in accordance with statutory and contractual requirements; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
- Provision of software and platform services: We process the data of our users, registered users, and any trial users to provide them with our contractual services and, on the basis of legitimate interests, to ensure the security of our offering and to continue developing it. The required information is indicated as such within the context of the order or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information enabling us to make any necessary follow-up inquiries; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Payment Procedures
In the context of contractual and other legal relationships, on the basis of legal obligations, or otherwise in accordance with our legitimate interests, we offer data subjects efficient and secure payment options and use banks and credit institutions as well as other service providers for this purpose (collectively referred to as "payment service providers"). Payment transactions are processed exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorized access during transmission.
The data processed by payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum, and recipient-related information. This information is required to carry out the transactions. However, the entered data is processed only by the payment service providers and stored with them. This means we do not receive account or credit card-related information, but only information confirming or declining the payment. Under certain circumstances, the data may be transmitted by payment service providers to credit agencies for identity and creditworthiness verification. We refer to the general terms and conditions and privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions; these are available on the respective websites or transaction applications. We also refer to these for further information and for exercising revocation, access, and other data subject rights.
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contractual data (e.g., subject matter of contract, term, customer category); 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, time information, identification numbers, persons involved).
- Data subjects: Recipients of services and clients; Business and contractual partners. Prospective customers.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and operational 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 inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Stripe: Payment processing 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 inquiries (Art. 6(1)(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 Offering and Web Hosting
We process user data in order 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, time information, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: 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.
- 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)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Provision of online offering on rented storage space: 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 bases: Legitimate interests (Art. 6(1)(f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of 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 may be used for security purposes, e.g., to avoid server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and to ensure server load and stability; Legal bases: 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 evidence purposes is exempt from deletion until the final clarification of the respective incident.
- Content delivery network: We use a "content delivery network" (CDN). A CDN is a service that helps deliver content of an online offering, particularly large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the internet; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Use of Cookies
The term "cookies" refers to functions that store and retrieve information on users' devices. Cookies may also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain prior consent from users. If consent is not required, we rely on our legitimate interests. This applies where the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent may be withdrawn at any time. We inform clearly about the scope of consent and the cookies used.
Notes on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If 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 duration: With regard to storage duration, the following types of cookies are distinguished:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest when a user leaves an online offering and closes their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, login status can be saved and preferred content can be displayed directly when the user revisits a website. Similarly, user data collected using cookies can be used for reach measurement. Unless we provide users with specific information about the type and storage duration of cookies, users should assume that cookies are permanent and that the storage duration can be up to two years.
General information on withdrawal and objection (opt-out): Users may withdraw consents they have given at any time and also object to processing in accordance with legal requirements, including by using the privacy settings in their browser.
- Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons 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 Activities, Procedures, and Services
- Processing of cookie data on the basis of consent: We use a consent management solution through which user consent for the use of cookies or the procedures and providers mentioned in the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consents, in particular with regard to the use of cookies and comparable technologies used to store, read out, and process information on users' devices. User consents for the use of cookies and the associated processing of information are obtained, including the specific processing activities and providers mentioned in the consent management procedure. Users also have the ability to manage and withdraw their consents. Consent declarations are stored in order to avoid repeated queries and to demonstrate consent in accordance with legal requirements. Storage takes place 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 consent to a specific user or their device. The duration of storage of the consent is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, the information about the scope of the consent, and information about the browser, system, and device used; Legal bases: Consent (Art. 6(1)(a) GDPR).
Registration, Login, and User Account
Users may create a user account. In the course of registration, users are informed of the required mandatory information, which is processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular login information (username, password, and an email address).
In the context of using our registration and login functions and the use of the user account, we store the IP address and the time of each user action. This storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and unauthorized use. This data is generally not passed on to third parties unless it is required to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions and the information relating to them, such as information on authorship or time of creation); 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). Log data (e.g., log files relating to logins or the retrieval of data or access times).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion". Deletion upon termination.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Registration with real names: Due to the nature of our community, we ask users to use our offering only under their real names. The use of pseudonyms is not permitted; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- Deletion of data upon termination: When users have terminated their user account, their data relating to the user account will be deleted, subject to a legal permission, obligation, or consent of the users; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
- No obligation to retain data: It is the responsibility of users to back up their data prior to the end of the contract in the event of termination. We are entitled to irrevocably delete all data stored by the user during the contract period; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Single Sign-On Authentication
"Single sign-on" or "single sign-on login or authentication" refers to procedures that allow users to log in to our online offering using a user account held with a provider of single sign-on services (e.g., a social network). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required credentials in the designated online form, 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 information that the user is logged in with the respective single sign-on provider under this user ID, 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, the data sharing options selected during authentication, and which data the users have made available in the privacy or other settings of their user account with the single sign-on provider. Depending on the single sign-on provider and the choices made by users, this may be various types of data; typically, these include the email address and the username. The password entered with the single sign-on provider as part of the single sign-on process is neither viewable by us nor stored by us.
Users are asked to note that their data stored with us may be automatically synchronized with their user account at the single sign-on provider, but this is not always possible or actually occurs. If, for example, users' email addresses change, they must change these manually in their user account with us.
We may use single sign-on authentication, if agreed with users, within the context of or prior to contract performance, as part of consent-based processing, and otherwise on the basis of our legitimate interests and the interests of users in an effective and secure login system.
If users decide at some point that they no longer wish to use the association of 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 from our system, they must cancel their registration with us.
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); 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, time information, 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 fulfillment of contractual obligations; Security measures; Registration procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion". Deletion upon termination.
- Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- OpenID Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information, and application integrations; Service provider: OpenID Foundation, 2400 Camino Ramon, Suite 375, San Ramon, CA 94583, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://openid.net; Privacy policy: https://openid.net/policies/. Basis for third-country transfers: Data Privacy Framework (DPF).
Contact and Inquiry Management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring parties is processed to the extent necessary to respond to the contact inquiries 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 and the information relating to them, such as information on authorship or time of creation). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- 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)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Contact form: When contacting us via our contact form, by email, or via other communication channels, we process the personal data transmitted to us to respond to and handle the respective inquiry. This generally includes information such as name, contact details, and where applicable further information communicated to us that is required for appropriate 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).
Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or on a statutory basis. If the content of the newsletter is described during registration, it is authoritative for the consent of users. Registration for our newsletter typically requires only the provision of your email address. However, in order to offer you a personalized service, we may ask for the provision of your name for personalized addressing in the newsletter, or for further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may retain the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to demonstrate a previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address for this purpose alone in a blocklist.
The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of demonstrating its proper conduct. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
Contents:
Information about us, our services, promotions, and offers.
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons 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. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Direct marketing (e.g., by email or postal). Provision of contractual services and fulfillment of contractual obligations.
- Legal bases: Consent (Art. 6(1)(a) GDPR).
- Right to object (opt-out): You may cancel the receipt of our newsletter at any time, i.e., withdraw your consent, or object to further receipt. A link to unsubscribe from the newsletter can be found either at the end of each newsletter, or you may otherwise use one of the contact options provided above, preferably email, for this purpose.
Further Notes on Processing Activities, Procedures, and Services
- Measurement of open rates and click rates: Newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server, or that of our mailing service provider if we use one, when the newsletter is opened. In the course of this retrieval, technical information such as information about the browser and system, as well as your IP address and the time of retrieval, is initially collected. This information is used for the technical improvement of our newsletter based on technical data or the target audiences and their reading behavior based on their retrieval locations; Legal bases: Consent (Art. 6(1)(a) GDPR).
- Requirement for using free services: Consents to the sending of mailings may be made a prerequisite for using free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without registering for the newsletter, please contact us.
Promotional Communication via Email, Post, Fax, or Telephone
We process personal data for the purposes of promotional communication, which may take place via various channels such as email, telephone, post, or fax, in accordance with legal requirements.
Recipients have the right to withdraw consents given at any time or to object to promotional communication free of charge at any time using the contact options provided above.
Following withdrawal or objection, we store the data required to demonstrate the prior authorization for contact or mailing for up to three years after the end of the year of the withdrawal or objection on the basis of our legitimate interests. Processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest to permanently observe the revocation or objection of users, we also store the data required to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, or name).
- Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or pictorial messages and contributions and the information relating to them, such as information on authorship or time of creation).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Direct marketing (e.g., by email or postal); Marketing. Sales promotion.
- Retention and deletion: Deletion in accordance with the information 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).
Web Analytics, Monitoring, and Optimization
Web analytics (also referred to as "reach measurement") is used to evaluate visitor flows to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can, for example, identify at what times our online offering or its functions or content are most frequently used, or which areas need optimization.
In addition to web analytics, we may also use testing procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles — i.e., data summarizing a usage process — may be created for these purposes, and information may be stored in a browser or on a device and then read out. The data collected includes in particular visited websites and elements used thereon, as well as technical information such as the browser used, the computer system, and information on usage times. If users have consented to the collection of their location data, location data may also be processed.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of users, but only the data stored in their profiles for the purpose of the respective procedures.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for the processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to 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 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, time information, identification numbers, persons involved).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
- 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 may be stored on users' devices for a period of up to two years).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number contains no unique data such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed within one or more usage sessions, which search terms they used, whether they accessed the content again, or whether they interacted with our online offering. The time of use and its duration are also stored, as well as the sources that led users to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics neither logs nor stores individual IP addresses for EU users. However, Analytics provides approximate geographic location data by deriving the following metadata from IP addresses: city (and derived latitude/longitude), continent, country, region, subcontinent. For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/.
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 would like to point out that user data may be processed outside the European Union. This may create risks for users, for example by making it more difficult to enforce user rights.
Furthermore, user data within social networks is typically processed for market research and advertising purposes. For example, usage profiles may be created based on users' behavior and the resulting interests. These may in turn be used to place advertisements, both within and outside the networks, that presumably correspond to the interests of users. For this reason, cookies are typically stored on users' computers in which the usage behavior and interests of users are recorded.
For a detailed presentation of the respective processing forms and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
Also in the case of access requests and the assertion of data subject rights, we point out that these can most effectively be asserted with the providers. Only the latter have access to the user data in each case and can take appropriate measures and provide information directly. Should you nevertheless require assistance, please feel free to contact us.
- 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 and the information relating to them, such as information on authorship or time of creation). 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: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
- 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)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Instagram: Social network that enables sharing of photos and videos, commenting on and liking posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: 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).
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, and the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, seniority level, company size, and employment status. Privacy information regarding LinkedIn's processing of user data can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum," https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects. The rights of users are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Right to object (opt-out): https://myadcenter.google.com/personalizationoff.
Plugins, Embedded Functions, and Content
We integrate functional and content elements into our online offering that are sourced from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or maps (hereinafter collectively referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of users, as without an IP address they would be unable to send the content to users' browsers. The IP address is therefore required for the display of this content or these functions. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" may be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may furthermore be stored in cookies on users' devices and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and further information about the use of our online offering.
Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services).
- 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, time information, identification numbers, persons 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 and legitimate interests: Provision of our online offering and user-friendliness; Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest-/behavior-based profiling, use of cookies); Audience targeting. Marketing.
- 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 may be stored on users' devices for a period of up to two years).
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further Notes on Processing Activities, Procedures, and Services
- Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or user-friendliness of our online offering). The respective providers collect the IP addresses of users and may process these for the purpose of transmitting the software to users' browsers and for security purposes, as well as for the evaluation and optimization of their offering; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
- Google Maps: We integrate maps from the "Google Maps" service provided by Google. The data processed may include in particular IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal bases: 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).
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://myadcenter.google.com/personalizationoff.
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We update the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will notify you as soon as the changes require an action on your part (e.g., consent) or other individual notification.
Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and we ask you to verify the information before making contact.
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Where terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- Employees: Employees are persons who are in an employment relationship, whether as workers, staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration, while the employee performs their work. The employment relationship encompasses various phases, including the establishment phase, in which the employment contract is concluded; the performance phase, in which the employee carries out their work; and the termination phase, when the employment relationship ends, whether by termination notice, mutual agreement, or otherwise. Employee data encompasses all information relating to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and banking data, working hours, vacation entitlements, health data, and performance evaluations.
- Master data: Master data encompasses key information necessary for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
- Content data: Content data encompasses 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 itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.
- Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools 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 the manner in which data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It may include information such as file size, creation date, the author of a document, and the history of changes. Communication data records the exchange of information between users across various channels, such as email correspondence, call logs, messages on social networks, and chat histories, including the parties involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and verifying operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data covers a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and along which paths they navigate through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services.
- 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., a 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: Processing of "profiles with user-related information," or simply "profiles" for short, includes any type of automated processing of personal data that consists of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
- Log data: Log data is information about events or activities that have been recorded 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 issues, for security monitoring, or for generating performance reports.
- Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as the content of websites. Using reach analysis, operators of online offerings can, for example, identify at what times users visit their websites and which content they are interested in, allowing them to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and features for location determination. Location data serves to indicate the geographically determinable position on the earth at which the respective device is located. Location data may be used, for example, to display map functions or other location-dependent information.
- Tracking: "Tracking" refers to the ability to trace the behavior of users across multiple online offerings. As a rule, behavioral and interest information with respect to the online offerings used is stored in cookies or on the servers of the providers of the tracking technologies (so-called profiling). This information may subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: A "controller" is the natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of processing personal data.
- Processing: "Processing" means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- Contractual data: Contractual data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged, or sold. This data category is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contractual data may include start and end dates of the contract, the nature of the agreed services or products, pricing arrangements, payment terms, cancellation rights, renewal options, and special conditions or clauses.
- Payment data: Payment data encompasses all information required to process payment transactions between buyers and sellers. This data is of critical importance for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.