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 as “data”) that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences such as our social media profiles (hereinafter collectively referred to as “Online Offering”).

The terms used are not gender-specific.

Last updated: May 27, 2026

Table of Contents

  • Preamble
  • Controller
  • Overview of Processing Activities
  • Applicable Legal Bases
  • Security Measures
  • Transfer of Personal Data
  • International Data Transfers
  • General Information on Data Storage and Deletion
  • Rights of Data Subjects
  • Provision of the Online Offering and Web Hosting
  • Use of Cookies
  • Blogs and Publication Media
  • Contact and Inquiry Management
  • Promotional Communication via Email, Post, Fax, or Telephone
  • Surveys and Questionnaires
  • Web Analytics, Monitoring, and Optimization
  • Privacy Information for Whistleblowers
  • Changes and Updates
  • Definitions

Controller

Björn Burghard c/o Block Services Stuttgarter Str. 106 70736 Fellbach Germany

Email address: contact@waycleft.com

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
  • Contact data
  • Content data
  • Usage data
  • Meta, communication, and procedural data
  • Log data

Categories of Data Subjects

  • Employees
  • Communication partners
  • Users
  • Participants
  • Third parties
  • Whistleblowers

Purposes of Processing

  • Communication
  • Security measures
  • Direct marketing
  • Reach measurement
  • Tracking
  • Organizational and administrative procedures
  • Feedback
  • Surveys and questionnaires
  • Marketing
  • Profiles with user-related information
  • Provision of our online offering and user-friendliness
  • Information technology infrastructure
  • Whistleblower protection
  • Sales promotion

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 or our country of residence or domicile. Should more specific legal bases be 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 for the implementation of pre-contractual measures taken at the request of the data subject.
  • 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, provided that such interests are not overridden by the interests, fundamental rights, and freedoms of the data subject which require the 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. This includes 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 the transfer of data as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual German federal states may apply.

Note on the applicability of the GDPR and the Swiss DPA: These privacy notices serve to provide information under both the Swiss Federal Act on Data Protection (DPA) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to their broader geographic applicability and comprehensibility. In particular, instead of the terms used in the Swiss DPA such as “processing” of “personal data,” “overriding interest,” and “particularly sensitive personal data,” the GDPR terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” are used. However, the legal meaning of the terms continues to be determined under the Swiss DPA within the scope of its applicability.

Applicability of data protection regulations in the country of domicile: In the country where the controller is domiciled, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

Security Measures

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

These measures include in particular ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to data, as well as access, input, transfer, availability assurance, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also consider the protection of personal data from the outset in the development or selection of hardware, software, and procedures, in accordance with the principles of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information 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 secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transfer of Personal Data

In the course of processing personal data, it may occur that such data is transferred to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and in particular enter into appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data processing in third countries: Where we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the context of using third-party services or disclosing or transferring data to other persons, entities, or companies (as indicated by the postal address of the respective provider or where the privacy policy explicitly references data transfers to third countries), this is always done in accordance with 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 adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers, which 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 layer of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur within the framework of the DPF, the Standard Contractual Clauses will serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses 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, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consent, 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 provisions as soon as the underlying consents are revoked or no further legal basis for processing exists. This applies to cases where the original processing purpose ceases to exist or the data is no longer needed. Exceptions to this rule exist where legal 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 legal proceedings or 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 operations.

Where multiple retention periods or deletion deadlines apply to a given piece of data, the longest period always prevails. Data that is no longer processed for its originally intended purpose but is retained due to legal requirements or other reasons will be processed exclusively for the reasons justifying its retention.

Commencement of deadlines at year-end: Where a deadline does not expressly begin on a specific date and amounts to at least one year, it automatically commences at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the date on which the termination takes effect or the legal relationship otherwise ends.

Rights of Data Subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right of access: You have the right to obtain confirmation as to whether personal data concerning you is being processed and to access 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 erased without undue delay, or alternatively to request restriction of the processing of such data in accordance with legal requirements.
  • 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 transfer to another controller, in accordance with legal requirements.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of the Online Offering and Web Hosting

We process users’ data in order to provide our online services. For this purpose, we process the user’s IP address, which is necessary to deliver 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 time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); log data (e.g., log files relating to logins, data retrieval, or access times); content data (e.g., text or image messages and posts as well as related information such as authorship details or time of creation).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; 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 provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of the online offering on rented server 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, 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 typically IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server capacity 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 necessary for evidentiary purposes is exempt from deletion until the final resolution of the respective incident.
  • Email sending and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information relating to email sending (e.g., the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of spam detection. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless end-to-end encryption is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and reception on our server; legal bases: legitimate interests (Art. 6(1)(f) GDPR).
  • HOSTINGER: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); service provider: HOSTINGER INTERNATIONAL LIMITED; 61 Lordou Vironos Street; Lumiel Building, 4th floor; CYP-6023 Larnaca; Cyprus; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.hostinger.de/; privacy policy: https://www.hostinger.de/datenschutz-bestimmungen; data processing agreement: https://www.hostinger.com/legal/dpa

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies may also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as for analyzing visitor traffic. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ prior consent. If consent is not required, we rely on our legitimate interests. This applies where the storage and reading of information is essential to provide explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent may be withdrawn at any time. We clearly inform users about the scope and which cookies are used.

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

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

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed 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 displayed directly when the user revisits a website. User data collected through cookies may also be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that cookies are permanent and may have a storage duration of up to two years.

General information on withdrawal and objection (opt-out): Users may withdraw their consent at any time and also file an objection to processing in accordance with legal requirements, including through the privacy settings of their browser.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); consent (Art. 6(1)(a) GDPR).

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a consent management solution through which users’ consent to the use of cookies or to the procedures and providers named in the consent management solution is obtained. This procedure serves to obtain, log, manage, and withdraw consent, in particular with regard to the use of cookies and comparable technologies used to store, read, and process information on users’ devices. As part of this procedure, users’ consent for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure, is obtained. Users also have the option to manage and withdraw their consent. Consent declarations are stored to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to be able to assign consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general information applies: The duration of consent storage is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used; legal bases: consent (Art. 6(1)(a) GDPR).

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only insofar as this is necessary for its presentation and communication between authors and readers, or for security reasons. For further information, we refer to the information on the processing of visitors to our publication medium within these privacy notices.

  • 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., text or image messages and posts as well as related information such as authorship details or time of creation); usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures.
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Retrieval of WordPress emojis and smilies: Within our WordPress blog, graphic emojis (or smilies), i.e., small graphic files expressing emotions, are used for the purpose of efficiently integrating content elements, retrieved from external servers. The server providers collect users’ IP addresses. This is necessary so that the emoji files can be delivered to users’ browsers; service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://automattic.com; privacy policy: https://automattic.com/privacy; data processing agreement: provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider).
  • Akismet anti-spam check: We use the “Akismet” service on the basis of our legitimate interests. Akismet is used to distinguish comments from real people from spam comments. For this purpose, all comment data is sent to a server in the USA, where it is analyzed and stored for comparison purposes for four days. If a comment has been classified as spam, the data is stored beyond this period. This data includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser and computer system used, and the time of entry. Users are welcome to use pseudonyms or to refrain from entering their name or email address. They can prevent the transmission of data entirely by not using our comment system. This would be unfortunate, but unfortunately we see no alternatives that work equally effectively; service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://automattic.com; privacy policy: https://automattic.com/privacy/; data processing agreement: provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider).
  • UpdraftPlus: Backup software and backup storage; service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://teamupdraft.com/updraftplus/; privacy policy: https://teamupdraft.com/privacy/.

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 persons is processed insofar as this is 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., text or image messages and posts as well as related information such as authorship details or time of creation); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; 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 provided 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 information on processing operations, procedures, and services:

  • Contact form: When contacting us via our contact form, email, or other communication channels, we process the personal data transmitted to us for the purpose of responding to and handling the respective inquiry. This typically includes information such as name, contact details, and, where applicable, further information communicated to us that is necessary 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).

Promotional Communication via Email, Post, Fax, or Telephone

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

Recipients have the right to withdraw their consent at any time or to object to promotional communication at any time free of charge via the contact options mentioned above.

After withdrawal or objection, we store the data necessary to prove the previous authorization for contact or dispatch 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 potential defense against claims. On the basis of our legitimate interest in permanently respecting 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, 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., text or image messages and posts as well as related information such as authorship details or time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post); marketing; sales promotion.
  • Retention and deletion: Deletion in accordance with the information provided 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).

Surveys and Questionnaires

We conduct surveys and questionnaires to collect information for the respectively communicated survey or questionnaire purpose. The surveys and questionnaires conducted by us (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed to the extent necessary for the provision and technical execution of the surveys (e.g., processing of the IP address to display the survey in the user’s browser, or using a cookie to enable resumption of the survey).

  • 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., text or image messages and posts as well as related information such as authorship details or time of creation); usage data (e.g., page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form); surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.”
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as “reach measurement”) serves to evaluate visitor traffic to our online offering and may encompass behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can identify, for example, at what time our online offering or its functions or content are used most frequently, or when they invite reuse. Similarly, we can determine which areas require optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles - i.e., data consolidated for a usage process - may be created for these purposes, and information may be stored in or read from a browser or device. The information collected includes in particular websites visited and elements used therein, as well as technical information such as the browser used, the computer system used, and information on usage times. Where users have consented to the collection of their location data by us or by the providers of the services we use, location data may also be processed.

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear-text 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 information 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 data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to 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 time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, identification of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest/behavior-based profiling, use of cookies); provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information provided 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).
  • 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 information on processing operations, procedures, and services:

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 to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of participation 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 please verify the information before contacting them.

Definitions

This section provides an overview of the terms used in this privacy policy. Where terms are legally defined, their legal definitions apply. The following explanations are intended primarily to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration, while the employee provides their work performance. The employment relationship encompasses various phases, including its establishment (when the employment contract is concluded), its execution (when the employee carries out their work), and its termination (when the employment relationship ends, whether through dismissal, termination agreement, or otherwise). Employee data refers to all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, leave entitlements, health data, and performance evaluations.
  • Master data: Master data encompasses essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions, or systems by enabling unambiguous identification and communication.
  • Content data: Content data encompasses information generated in the course of creating, editing, and publishing content of all types. 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 is essential information that enables communication with persons or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • 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 that describes the context, origin, and structure of other data. It may include information on file size, creation date, document author, and change histories. Communication data records the exchange of information between users through various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used for tracking and verifying operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information that shows how users use applications, which features they prefer, how long they spend on certain pages, and the paths through which they navigate an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a critical role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more 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, encompasses any form of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.), to analyze or predict them (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used for analyzing system problems, security monitoring, or generating performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate visitor traffic to an online offering and may encompass the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can identify, for example, at what time users visit their websites and what content they are interested in. This enables them, for example, to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to identify returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Tracking: “Tracking” refers to the ability to trace users’ behavior across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the tracking technology providers (so-called profiling) with regard to the online offerings used. This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether collection, evaluation, storage, transmission, or deletion.

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