Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

Date: November 17, 2025

Table of Contents

• Preamble
• Controller
• Overview of Processing
• Relevant Legal Bases
• Security Measures
• Transmission of Personal Data
• International Data Transfers
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Provision of Online Offering and Web Hosting
• Registration, Login and User Account
• Single Sign-On Login
• Blogs and Publication Media
• Contact and Inquiry Management
• Newsletter and Electronic Notifications
• Promotional Communication via Email, Post, Fax or Telephone
• Plugins and Embedded Functions and Content
• Privacy Information for Whistleblowers
• Changes and Updates
• Definitions of Terms

Controller

Ante Simon Brähler
Hambacherstraße, 24
64625 Bensheim, Germany

Email address: webqrapp@gmail.com

Phone: +49 171 8285405

Legal Notice: https://webqr.app/legal-notice

Overview of Processing

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

Types of Data Processed

• Inventory data.
• Employee data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of Data Subjects

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

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Direct marketing.
• Organizational and administrative procedures.
• Feedback.
• Marketing.
• Login procedures.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Whistleblower protection.
• Sales promotion.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of personal data relating to them for one or more specific purposes.
• Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the German Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

In accordance with legal requirements and 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 the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, disclosure, ensuring availability and separation of data. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and responses to data threats. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt information transmitted between the website or app and the user's browser (or between two servers), thereby protecting data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured with an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and encrypted.

Transmission of Personal Data

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

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using third-party services or disclosing or transferring data to other persons, entities or companies (which is recognizable from the postal address of the respective provider or if the privacy policy expressly refers to data transfer 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 dated July 10, 2023. Additionally, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

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

For individual service providers, we inform you whether they are DPF-certified 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 U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

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

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or there are no longer any legal bases for processing. This applies to cases where the original processing purpose ceases to apply or the data is no longer required. Exceptions to this rule exist when 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 prosecution or to protect 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 is specific to certain processing processes.

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 the originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

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

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

Start of deadline at the end of the year: If a deadline does not expressly start on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the deadline is the time when the termination becomes effective or other termination of the legal relationship.

Rights of Data Subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consent at any time.
• Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this 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 immediately, or alternatively to request restriction of the processing of the data in accordance with legal requirements.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
• Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.

Provision of Online Offering and Web Hosting

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved). Log data (e.g. log files concerning logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: 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 information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, 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 from or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Provision of online offering on own/dedicated server hardware: For the provision of our online offering, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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". The server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
• STRATO: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz/. Data processing agreement: Provided by the service provider.

The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter "Strato"). When you visit our website, Strato collects various log files including your IP addresses. Further information can be found in Strato's privacy policy: https://www.strato.de/datenschutz/.

The use of Strato is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the most reliable presentation possible of our website. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that this service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Registration, Login and User Account

Users can create a user account. As part of the registration, users are informed of the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (user name, password and an email address).

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of users in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

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

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as author information or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Log data (e.g. log files concerning logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of 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 information in the section "General Information on Data Storage and Deletion". Deletion after termination.
• Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Registration with pseudonyms: Users may use pseudonyms instead of real names as user names; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• User profiles are not public: User profiles are not publicly visible and not accessible.
• Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, you must perform an additional authentication measure in addition to your password (e.g. enter a code sent to a mobile device). We will inform you about the procedure we use; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to legal permission, obligation or consent of the users; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• No obligation to retain data: It is the users' responsibility to back up their data before the end of the contract in the event of termination. We are entitled to irrevocably delete all data stored during the contract period; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Single Sign-On Login

"Single Sign-On" or "Single Sign-On login or authentication" refers to procedures that allow users to log in to our online offering using a user account with a Single Sign-On provider (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 access data in the online form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via button.

Authentication takes place directly with the respective Single Sign-On provider. As part of such authentication, we receive a user ID with the information that the user is logged in under this user ID with the respective Single Sign-On provider and an ID that is not further usable for us for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the Single Sign-On procedure used, on the data releases selected during authentication and also on which data users have released in the privacy or other settings of the user account with the Single Sign-On provider. Depending on the Single Sign-On provider and the users' choice, different data may be involved; usually it is the email address and user name. The password entered as part of the Single Sign-On procedure with the Single Sign-On provider is neither visible to us nor is it stored by us.

Users are asked to note that their data stored with us may be automatically synchronized with their user account with the Single Sign-On provider, but this is not always possible or actually happens. If, for example, users' email addresses change, they must change them manually in their user account with us.

We can use Single Sign-On login, if agreed with users, as part of or before contract fulfillment, insofar as users have been asked to do so, process it as part of consent and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure login system.

Should users decide at some point not to want to use the link between their user account with the Single Sign-On provider for the Single Sign-On procedure anymore, they must cancel this connection within their user account with the Single Sign-On provider. If users want to delete their data with us, they must terminate their registration with us.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Login procedures. Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion". Deletion after termination.
• Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Settings for displaying ads: https://myadcenter.google.com/.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within this privacy policy.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as author information or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Contact and Inquiry Management

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

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as author information or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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 to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, further information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or on a legal basis. If, as part of a registration for the newsletter, its contents are mentioned, these contents are decisive for the consent of the users. For registration to our newsletter, the provision of your email address is normally sufficient. However, to be able to offer you a personalized service, we may ask for your name for a personal salutation in the newsletter or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them, in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided 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 process is based on our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Contents:

Information about us, our services, promotions and offers.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Communication partners.
• Purposes of processing: Direct marketing (e.g. by email or post).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Opt-out option: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably email, for this purpose.

Further information on processing operations, procedures and services:

• Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from their server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of measurement results in user profiles. (Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Promotional Communication via Email, Post, Fax or Telephone

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

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

After revocation or objection, we store the data required to prove previous authorization to contact or send for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest in permanently observing the users' revocation or objection, we also store the data necessary to avoid renewed contact (e.g. depending on the communication channel, the email address, telephone number, name).

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as author information or time of creation).
• Data subjects: Communication partners.
• Purposes of processing: Direct marketing (e.g. by email or post); Marketing. Sales promotion.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").

Integration always requires that the third-party providers of this content process the IP address of users, as they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users' devices for a period of two years).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

• Google Fonts (obtained from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible licensing restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent that describes the browser and operating system versions of website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referral URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must customize the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on Google Fonts' "Analytics" page. Finally, the referral URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to display targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

Privacy Information for Whistleblowers

In this section you will find information about how we handle data from people who provide information (whistleblowers) as well as from affected and involved parties within the framework of our whistleblower procedure. Our goal is to provide a straightforward and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws.

Legal bases (Germany): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 para. 1 sentence 1 lit. c) GDPR and in the case of special categories of personal data Art. 9 para. 2 lit. g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This refers to the obligation to set up and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the case of using the data collected in the reporting procedure, taking further investigations or labor law steps against persons who have been convicted of a violation.

Insofar as we process data (especially in the case of established misconduct) within the framework of or in preparation for legal defense, this is done on the basis of our legitimate interests in legally compliant and ethical conduct in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

If you have given us consent to process personal data for certain purposes, processing is carried out on this basis in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR.

Types of data processed:

As part of receiving and processing information as well as in the subsequent whistleblower procedure, we may collect various data. This includes in particular the data provided by a whistleblower, such as:

• Name, contact details and whereabouts of the person providing the information,
• Names and data on possible witnesses or persons affected by the information,
• Names and data on the persons against whom the information is directed,
• Data on the alleged misconduct,
• Further relevant details, if communicated by the whistleblower.

For the purposes of fact-checking and further proceedings, we also process the following personal data:

• Unique identification of the report,
• Contact details of the reporting person, if provided,
• Personal data of persons mentioned in the report, if provided,
• Personal data of persons indirectly affected by the report.

Special categories of personal data:

It may happen that we collect special types of personal data as part of our activities, especially when this is communicated by a whistleblower. These include:

• Health-related data of a person,
• Data on a person's racial or ethnic origin,
• Information about a person's religious or philosophical beliefs,
• Information about a person's sexual orientation.

This data is only processed if it is absolutely necessary for the purposes of processing the information and we either have explicit consent from the person concerned or a legal basis permits this.

Use of our online forms: Please note that it is possible to submit information anonymously. To ensure the security of your data when using our online forms, we recommend calling them up in the so-called 'incognito mode' of your browser. Here's how to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When accessing our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your end device. This data is stored temporarily in a log file and automatically deleted after 30 days at the latest.

The processing of the IP address serves technical and administrative purposes of establishing a connection to our website. It ensures the security, stability and functionality of the whistleblower form and is an important part of our measures to ensure data protection and data security. The legal basis for processing the IP address is Art. 6 para. 1 sentence 1 lit. f) GDPR.

Providing names: You have the option to submit information anonymously. However, unless prohibited by national legislation, we recommend providing your name and contact details. This enables us to follow up on the report more effectively and, if necessary, contact you directly.

If you provide your name and contact details, your identity will be treated strictly confidentially. Exceptions to this confidentiality only exist if we are legally obliged to disclose your identity. This may be necessary to protect our rights or the rights of our employees, customers, suppliers or business partners, or if it is required to clarify alleged misconduct.

Provision of data to third parties: Data related to the submitted information is only passed on by us to third parties under certain circumstances. This happens either a) if you have given us your express consent to do so, or b) if there is a legal obligation to pass on the data. Possible third parties include public authorities, governmental, regulatory or tax authorities if the disclosure is necessary to fulfill a legal or regulatory obligation. In addition, within the framework of legal provisions, we may commission lawyers and other professional advisors. These are authorized to examine alleged misconduct and take necessary measures after an investigation, such as initiating disciplinary or legal proceedings. In addition, carefully selected and monitored service providers may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations as part of data processing.

Data retention and deletion: Personal data is only processed for as long as is necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations, however, the data may be retained for longer to meet legal requirements, as long as this is necessary and proportionate. In such cases, the data is protected in accordance with applicable data protection regulations.

Technical and organizational measures: We have implemented the necessary contractual, technical and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes. Incoming information is processed by authorized persons who have access to the respective information and carry out the subsequent review of the facts. Our employees are specially trained and obliged to maintain confidentiality.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number). Employee data (information about employees and other persons). Contact data (e.g. postal and email addresses) or content data (e.g. textual or pictorial messages and posts as well as information relating to them, such as author information). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions).
• Data subjects: Employees. Third parties. Whistleblowers.
• Purposes of processing: Whistleblower protection.
• Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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 action on your part (e.g. consent) or other individual notification.

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

Definitions of Terms

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

• Employees: Employees are persons who are in an employment relationship, whether as workers, 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 includes various phases, including establishment, in which the employment contract is concluded, performance, in which the employee carries out their work, and termination, when the employment relationship ends, whether through termination, termination agreement or otherwise. Employee data is all information that relates to these persons and is in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, vacation entitlements, health data and performance assessments.
• Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities or systems by enabling unique assignment and communication.
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data 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 persons or organizations. It includes telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about how data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It may include information about file size, creation date, author of a document and change histories. Communication data captures the exchange of information between users via 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, logs of transactions and activities, as well as audit logs used to track and review operations.