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 personal data processing activities we undertake, 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 offer”). The terms used are not gender-specific. Date: March 11, 2024

Preamble
Controller
Overview of Processing
Relevant Legal Bases
Security Measures
Transfer of Personal Data
International Data Transfers
Rights of the Data Subjects
Use of Cookies
Business Services
Payment Procedures
Provision of the Online Offer and Web Hosting
Blogs and Publication Media
Contact and Inquiry Management
Newsletters and Electronic Notifications
Web Analysis, Monitoring, and Optimization
Online Marketing
Presence in Social Networks (Social Media)
Plugins and Embedded Functions as well as Content

Controller

BeniHaus Maroc coop, email address: [email protected]

Overview of Processing

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

Types of processed data:

Inventory data
Payment data
Contact data
Content data
Contract data
Usage data
Meta, communication, and procedural data

Categories of data subjects:

Customers
Interested parties
Communication partners
Users
Business and contractual partners

Purposes of processing:

Provision of contractual services and fulfillment of contractual obligations
Contact inquiries and communication
Security measures
Direct marketing
Reach measurement
Tracking
Office and organizational procedures
Conversion measurement
Administration and response to inquiries
Feedback
Marketing
Profiles with user-related information
Provision of our online offer and user-friendliness
Information technology infrastructure

Relevant Legal Bases

Security Measures

In accordance with legal requirements, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. 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 the related access, input, transfer, ensuring availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take into account the protection of personal data in 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.

TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.

Transfer of Personal Data

In the context of our processing of personal data, it may occur that the data is transmitted to other locations, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of these data may include service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we comply with the legal requirements and conclude appropriate contracts or agreements with the recipients of your data to protect your data.

Data transfer within the organization: We may transfer personal data to other locations within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is necessary for the fulfillment of our contractual obligations, or if consent from the data subjects or legal permission is present.

International Data Transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)), or if processing occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, offices, or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by a decision of adequacy (Art. 45 GDPR), this serves as the basis for the data transfer. Additionally, data transfers will only occur if the level of data protection is otherwise guaranteed, in particular through contractual obligations (so-called standard contractual clauses – Art. 46 para. 2 lit. c GDPR), express consent, or if the transfer is contractually or legally required (Art. 49 para. 1 GDPR). We also inform you about the basis of the transfers to third countries for the various service providers from third countries, with adequacy decisions being prioritized as basic principles. Information about transfers to third countries and existing adequacy decisions can be found in the information offer of the European Commission: European Commission Data Protection.

Rights of the Data Subjects

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

Right to object: You have the right to object at any time to the processing of your personal data, which is based on Art. 6 para. 1 lit. e or f GDPR, for reasons arising from your particular situation; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such advertising purposes; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw any consent given at any time.
Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as to further information and a copy of the data in accordance with the legal requirements.
Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the legal requirements.
Right to erasure and restriction of processing: You have the right to request that data concerning you be deleted immediately in accordance with the legal requirements, or alternatively, to request a restriction of the processing of the data in accordance with the legal requirements.
Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with the legal requirements, or to request the transfer to another controller.
Complaint to a supervisory authority: You have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy, particularly in the member state of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your personal data infringes the provisions of the GDPR.

Use of Cookies

Cookies are small text files or other memory notes that store information on end devices and read information from end devices. For example, to save the login status in a user account, a shopping cart content in an online shop, the accessed content, or used functions of an online offer. Cookies can also be used for different purposes, e.g., for the functionality, security, and comfort of online offers as well as for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly not necessary if the storage and reading of the information, including cookies, is absolutely necessary to provide the user with a telemedia service they expressly requested (i.e., our online offer). The absolutely necessary cookies usually include cookies with functions that are essential for the display and operability of the online offer, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online offer requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie usage.

Notes on legal bases for data protection: The legal basis on which we process the personal data of users using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is based on our legitimate interests (e.g., in the business operation of our online offer and its improvement of usability) or if the use of cookies is necessary to fulfill our contractual obligations if the use of cookies is required to fulfill our contractual obligations. We explain for what purposes the cookies are processed in the course of this privacy policy or in the context of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left the website.

Business Services
We process data of our contractual and business partners, such as customers and prospects (collectively referred to as “contract partners”) in the context of contractual and similar legal relationships and associated measures, as well as during communication with the contract partners (or pre-contractually), for example, to respond to inquiries. We process this data to fulfill our contractual obligations. This includes, in particular, obligations related to providing agreed services, any update obligations, and remedying warranty and other service disruptions. Furthermore, we process the data to protect our rights and for administrative tasks related to these obligations and business organization. Additionally, we process the data based on our legitimate interests in proper and efficient business management and in security measures to protect our contract partners and our business operations from misuse, threats to their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). In accordance with applicable law, we only disclose contract partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contract partners will be informed of further forms of processing, such as for marketing purposes, within the framework of this privacy policy. We inform the contract partners of the data required for the aforementioned purposes before or during data collection, for example, in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks), or personally. We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons (e.g., internal storage of customer data, order processes, or invoices). The statutory retention period is ten years for tax-relevant documents and for commercial books, inventories, opening balances, annual financial statements, work instructions required to understand these documents, and other organizational documents and booking receipts, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance, annual financial statement, or management report was prepared, the commercial or business letter was received or sent, or the booking receipt was created, and further, the recording was made or the other documents were created. If we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between users and providers.
Processed Data Types: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., email, phone numbers); Contract data (e.g., subject matter of the contract, duration, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected Persons: Customers; Prospects; Business and contract partners.
Purposes of Processing: Providing contractual services and fulfilling contractual obligations; Security measures; Contact inquiries and communication; Office and organizational procedures; Administration and response to inquiries; Conversion measurement (measuring the effectiveness of marketing measures). Profiles with user-related information (creating user profiles).
Legal Bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR); Legal obligations (Art. 6 (1) sentence 1 lit. c GDPR). Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
Further Information on Processing Processes, Procedures, and Services:

Customer Account: Customers can create an account within our online offer (e.g., customer or user account, “customer account” for short). If the registration of a customer account is required, customers will be informed about it as well as the necessary details for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the customer account, we store the IP addresses of the customers along with access times to prove registration and to prevent misuse of the customer account. If the customer account is terminated, the data of the customer account will be deleted after the termination date unless it is retained for purposes other than providing the customer account or for legal reasons (e.g., internal storage of customer data, order processes, or invoices). It is the responsibility of the customers to secure their data upon termination of the customer account; Legal Bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).

Economic Analysis and Market Research: For business reasons and to identify market trends, customer preferences, and user needs, we analyze the data available to us regarding business transactions, contracts, inquiries, etc., which may include contract partners, prospects, customers, visitors, and users of our online offer. The analyses are carried out for the purposes of business evaluations, marketing, and market research (e.g., determining customer groups with different characteristics). We may consider the profiles of registered users and their details, such as services used, if available. The analyses are for our use only and are not disclosed externally, except for anonymous analyses with aggregated, anonymized values. Additionally, we take user privacy into account and process data for analytical purposes as pseudonymously and, if possible, anonymously (e.g., as aggregated data); Legal Bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Online Shop, Order Forms, E-Commerce, and Delivery: We process customer data to enable the selection, purchase, or order of selected products, goods, and associated services, as well as their payment and delivery or execution. If necessary for order execution, we use service providers, particularly postal, freight, and shipping companies, to carry out delivery or execution for our customers. For processing payment transactions, we use the services of banks and payment service providers. The required details are marked as such during the order or similar acquisition process and include the information needed for delivery, provision, and invoicing, as well as contact information for any necessary communication; Legal Bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).

Payment Methods:
In the context of contractual and other legal relationships, due to legal obligations or based on our legitimate interests, we offer affected persons efficient and secure payment options and use, in addition to banks and credit institutions, other service providers (collectively “payment service providers”).
Data processed by payment service providers include inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checks, as well as contract, amount, and recipient-related information. The details are required to process transactions. However, the entered data is only processed and stored by the payment service providers. This means that we do not receive account or credit card-related information but only information confirming or denying the payment. Payment service providers may transmit data to credit agencies for identity and credit checks. For this, we refer to the terms and conditions and privacy notices of the payment service providers. For payment transactions, the terms and conditions and privacy notices of the respective payment service providers apply, which can be accessed on their respective websites or transaction applications. We refer to these for further information and assertion of withdrawal, information, and other affected rights.
Processed Data Types: Inventory data (e.g., names, addresses); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, duration, customer category); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected Persons: Customers; Prospects.
Purposes of Processing: Providing contractual services and fulfilling contractual obligations.
Legal Bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).
Further Information on Processing Processes, Procedures, and Services:

PayPal: Payment services (technical integration of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Provision of the Online Offer and Web Hosting
We process user data to provide 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 device.
Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected Persons: Users (e.g., website visitors, online service users).
Purposes of Processing: Providing our online offer and user friendliness; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
Legal Bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
Further Information on Processing Processes, Procedures, and Services:

Collection of Access Data and Log Files: We collect data on every access to the server hosting our website (so-called server log files). The access data includes the IP address, date and time of access, the amount of data sent, the website from which the access originated, the browser used, and other data and information related to the operating system. This data is used for security purposes to ensure the stability and integrity of the server and the website, to prevent misuse and to perform necessary maintenance tasks. The data is only analyzed in an anonymous form and only for statistical purposes. In the case of security incidents or misuse, we may review and investigate log files with identifiable data, but this is done in a regulated manner to protect the privacy of users and only if necessary. The data is deleted after the purpose of its collection has been fulfilled.

Web Hosting Services: To provide our online offer efficiently and securely, we use the services of web hosting providers. They process the user data necessary to provide the online offer and may also use cookies, web storage, or other methods to optimize the delivery of our online offer.
Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
Affected Persons: Users (e.g., website visitors, online service users).
Purposes of Processing: Providing our online offer and user friendliness; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
Legal Bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
Further Information on Processing Processes, Procedures, and Services: The respective web hosting provider is mentioned in the data protection notices and terms of service of our website.

Newsletter and Electronic Notifications We send newsletters, emails, and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or with legal permission. If the contents of the newsletter are specifically described during the registration process, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us. To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal address in the newsletter or other information if required for the purposes of the newsletter.

Double-Opt-In Procedure: Subscription to our newsletter is carried out in a so-called double-opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with someone else’s email address. The registrations for the newsletter are logged to prove the registration process according to legal requirements. This includes storing the registration and confirmation time and the IP address. Changes to your data stored with the email service provider are also logged.

Deletion and Restriction of Processing: We can store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove previously given consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a 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 solely for this purpose in a blacklist (so-called “blocklist”).

The logging of the registration procedure is based on our legitimate interests for the purpose of proving its proper conduct. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure sending system.

Contents: Information about us, our services, actions, and offers.

Processed Data Types: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status); usage data (e.g., visited websites, interest in content, access times).

Affected Persons: Communication partners.

Purposes of Processing: Direct marketing (e.g., via email or mail).

Legal Bases: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Objection Option (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e., withdraw your consent, or object to further receipt. A link to cancel the newsletter can be found either at the end of each newsletter or you can use one of the above contact options, preferably email.

Further Information on Processing Procedures, Procedures, and Services: Mailchimp: Email marketing, automation of marketing processes, collection, storage, and management of contact data, measurement of campaign performance, collection and analysis of recipients’ interactions with content, personalization of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal bases: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/; Data Processing Agreement: https://mailchimp.com/legal/; Third country transfer basis: Data Privacy Framework (DPF). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.

Web Analysis, Monitoring, and Optimization Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offer and can include behavior, interests, or demographic information about visitors, such as age or gender, in pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite reuse. Similarly, we can identify which areas need optimization.

In addition to web analysis, we can also use test procedures to test and optimize different versions of our online offer or its components.

Unless otherwise specified below, profiles, i.e., data summarized for a usage process, can be created and information can be stored and read in a browser or an end device for these purposes. The collected information includes, in particular, visited websites and the elements used there as well as technical information, such as the browser used, the computer system used, and information about usage times. If users have consented to the collection of their location data, we can also process these.

Users’ IP addresses are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, the clear data of users (such as email addresses or names) are not stored in the context of web analysis, A/B testing, and optimization but rather pseudonyms. This means that we and the providers of the used software do not know the actual identity of the users, but only the data stored in their profiles for the respective processes.

Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).

Affected Persons: Users (e.g., website visitors, users of online services).

Purposes of Processing: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles). Provision of our online offer and user-friendliness.

Security Measures: IP masking (pseudonymization of the IP address).

Legal Bases: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).

Further Information on Processing Procedures, Procedures, and Services: Google Analytics: We use Google Analytics to measure and analyze the use of our online offer based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It serves to assign analysis information to a device to recognize which content users have accessed within one or multiple usage processes, which search terms they used, accessed again, or interacted with our online offer. Likewise, the usage time and duration are stored, as well as the sources of users who refer to our online offer and technical aspects of their devices and browsers.

Pseudonymous profiles of users are created with information from the use of various devices, using cookies. Google Analytics does not log or store individual IP addresses for EU users. Analytics, however, provides coarse geographical location data by deriving the following metadata from IP addresses: city (and derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, the IP address data is used exclusively for deriving geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP address queries are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Third country transfer basis: Data Privacy Framework (DPF); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).

Online Marketing

We process personal data for the purposes of online marketing, which may include the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on potential user interests as well as measuring their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, whereby relevant information about the user for displaying the aforementioned content is stored. This information may include viewed content, visited websites, used online networks, but also communication partners and technical information such as the browser used, the computer system used, as well as information on usage times and used functions. If users have consented to the collection of their location data, this may also be processed.

IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. Generally, no clear data of the users (such as email addresses or names) is stored within the framework of online marketing procedures, but pseudonyms. This means that neither we nor the providers of online marketing procedures know the actual identity of the users, only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by using similar procedures. These cookies can generally be read and analyzed on other websites that use the same online marketing procedure, for the purpose of displaying content, as well as supplemented with other data and stored on the server of the online marketing procedure provider.

In exceptional cases, clear data can be associated with the profiles. This is the case if users are, for example, members of a social network whose online marketing procedures we use and the network links the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example, by giving consent within the framework of registration.

We generally only receive access to aggregated information about the success of our advertisements. However, we can check within the framework of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that the cookies used will be stored for a period of two years.

Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).

Affected Persons: Users (e.g., website visitors, users of online services).

Purposes of Processing: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-based profiling, use of cookies); Marketing; Profiles with user-related information (creating user profiles). Conversion measurement (measuring the effectiveness of marketing measures).

Security Measures: IP masking (pseudonymization of the IP address).

Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Opt-Out Possibility: We refer to the data protection notices of the respective providers and the opt-out options provided by the providers (so-called “opt-out”). If no explicit opt-out option has been specified, there is the possibility that you can disable cookies in your browser settings. However, this may limit the functions of our online offer. Therefore, we also recommend the following opt-out options, which are offered in a summarized form for each region:

a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-region: https://optout.aboutads.info.

Further Information on Processing Procedures, Methods, and Services:

Google Ads and Conversion Measurement: Online marketing method for placing content and advertisements within the service provider’s advertising network (e.g., in search results, in videos, on websites, etc.), so that they are displayed to users who presumably have an interest in the advertisements. Furthermore, we measure the conversion of the ads, i.e., whether users have taken the opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis of third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices. Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Presences in Social Networks (Social Media)

We maintain online presences within social networks and process user data within this framework to communicate with the users active there or to offer information about us.

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

Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can, in turn, be used to, for example, place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and logged in to them).

For a detailed presentation of the respective processing forms and the opt-out options, we refer to the privacy statements and information of the operators of the respective networks.

Also, in the case of information requests and the assertion of data subject rights, we point out that these are most effectively asserted with the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. If you still need help, you can contact us.

Processed Data Types: Contact data (e.g., email, telephone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).

Affected Persons: Users (e.g., website visitors, users of online services).

Purposes of Processing: Contact inquiries and communication; Feedback (e.g., collecting feedback via online form). Marketing.

Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further Information on Processing Procedures, Methods, and Services:

Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. Basis of third-country transfers: Data Privacy Framework (DPF).

Facebook Pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis of third-country transfers: Data Privacy Framework (DPF); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “Fanpage”). This data includes information about the types of content that users view or interact with, or the actions they take (see “Things done and provided by you and others” in Facebook’s Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in Facebook’s Data Policy: https://www.facebook.com/policy). As explained in Facebook’s Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights,” to page operators so that they can gain insights into how people interact with their pages and the associated content. We have entered into a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures that Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data).

Plugins and Embedded Functions, and Content

We integrate functional and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos, or social media buttons, as well as posts (hereinafter uniformly referred to as “content”).

The integration always presupposes that the third-party providers of this content process the IP address of the users because they could not send the content to their browser without the IP address. The IP address is, therefore, necessary for displaying this content or functionality. We strive to use only such content whose respective providers use the IP address solely for delivering the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information can be evaluated, such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the users’ devices and may contain technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offer as well as be linked to such information from other sources.

Affected Persons: Users (e.g., website visitors, users of online services).

Purposes of Processing: Provision of our online offer and user-friendliness. Integration of third-party content.

Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further Information on Processing Procedures, Methods, and Services:

Instagram Plugins and Content: Social plugins and content – This can include content such as images, videos, or text and buttons that allow users to share content from this online offer within Instagram. Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. Basis of third-country transfers: Data Privacy Framework (DPF).

Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free, and efficient use of fonts, their uniform presentation, and considering possible licensing restrictions for their integration. 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.

Font Awesome (Hosting on Own Server): Display of fonts and icons; Service Provider: The Font Awesome icons are hosted on our server, and no data is transmitted to the provider of Font Awesome; Legal Basis: Legitimate Interests (Art. 6(1) Sentence 1 lit. f) GDPR).

Google Maps: We integrate maps from the “Google Maps” service provided by Google. The processed data may include IP addresses and location data of the users; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Consent (Art. 6(1) Sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/. Privacy Policy: https://policies.google.com/privacy.

YouTube Videos: Video content; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6(1) Sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy. Opt-Out Option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for Ad Personalization: https://myadcenter.google.com/personalizationoff.

Privacy Information for Whistleblowers

In this section, you will find information about how we handle data from individuals who provide tips (whistleblowers), as well as data from affected and involved parties within the framework of our whistleblower procedure.

Legal Basis (Germany): As far 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(1)(c) GDPR, and in the case of special categories of personal data, Article 9(2)(g) GDPR, Section 22 BDSG, each in conjunction with Section 10 HinSchG. This pertains to the obligation to establish and operate an internal whistleblower reporting office, fulfill its legal duties, and, in the event of using the data collected in the reporting process, take further investigations or employment law actions against individuals found guilty of violations.

As far as we process data (especially in the case of detected misconduct) in the context of or for the preparation of legal defense, this is done based on our legitimate interests in lawful and ethical conduct in accordance with Article 6(1)(f) GDPR.

If you have given us consent to process personal data for specific purposes, the processing is based on this consent according to Article 6(1)(a) GDPR.

Types of Data Processed: Inventory data (e.g., full name, home address, contact information, customer number…).

Affected Persons: Employees (e.g., employees, applicants…); third parties; whistleblowers.

Purposes of Processing: Whistleblower protection.

Retention and Deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion.”

Legal Basis: Consent (Article 6(1)(a) GDPR); Legal Obligation (Article 6(1)(c) GDPR); Legitimate Interests (Article 6(1)(f) GDPR).

Amendments and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as changes require your cooperation (e.g., consent) or any 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 we ask you to verify the information before contacting them.

Definitions

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

Affiliate Tracking: In affiliate tracking, links that refer users from linking websites to websites with product or other offers are logged. The operators of the respective linking websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). It is necessary for providers to track whether users who are interested in certain offers subsequently use them based on the affiliate links. Therefore, it is necessary for the functionality of affiliate links that they are supplemented with certain values that become part of the link or are stored elsewhere, e.g., in a cookie. These values include, in particular, the originating website (referrer), the time, an online identifier of the operators of the website where the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values, such as ad media ID, partner ID, and categorizations.

Employees: Employees are individuals 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, established by an employment contract or agreement. It involves the employer’s obligation to pay the employee compensation while the employee provides their work. The employment relationship includes various phases, including the establishment (where the employment contract is concluded), the execution (where the employee performs their work), and the termination (when the employment relationship ends, whether by termination, mutual agreement, or otherwise). Employee data refers to all information related to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance evaluations.

Inventory Data: Inventory data includes essential information necessary for the identification and management of contract partners, user accounts, profiles, and similar assignments. These data can include personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birthdates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling clear assignment and communication.

Firewall: A firewall is a security system that protects a computer network or a single computer from unwanted network access.

Content Data: Content data includes information generated in the creation, editing, and publication of all kinds of content. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the 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 are essential information that enables communication with individuals or organizations. This includes, among others, phone numbers, postal addresses, and email addresses, as well as communication tools like social media handles and instant messaging identifiers.

Conversion Tracking: Conversion tracking (also known as “visitor action evaluation”) is a process used to determine the effectiveness of marketing measures. Usually, a cookie is stored on users’ devices within the websites where marketing measures occur and then retrieved on the target website. For example, we can track whether the ads we place on other websites were successful.

Meta, Communication, and Procedural Data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, includes information that describes the context, origin, and structure of other data. This can include information such as file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across 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 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 wide range of information that shows how users utilize applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data can also include the frequency of use, activity timestamps, IP addresses, device information, and location data. This data is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Additionally, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.

Personal Data: “Personal data” is any information relating to an identified or identifiable natural person (hereinafter referred to as “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 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 simply “profiles” involves any type of automated processing of personal data used to analyze, evaluate, or predict certain personal aspects related to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc.). For profiling purposes, cookies and web beacons are often used.

Log Data: Log data is information about events or activities that have been logged in a system or network. This data typically includes 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, monitoring security, or generating performance reports.

Reach Measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include analyzing visitor behavior or interests in specific information, such as website content. With the help of reach analysis, online offering operators can, for example, identify when users visit their websites and which content they are interested in. This allows them to better tailor website content to visitors’ needs. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and obtain more accurate analyses of the use of an online offering.

Location Data: Location data is generated when a mobile device (or another device with technical capabilities for location determination) connects to a cell tower, Wi-Fi, or similar technical means and functions for location determination. Location data indicates the geographical position on Earth where the respective device is located. Location data can, for example, be used to display map functions or other location-dependent information.

Tracking: “Tracking” refers to monitoring user behavior across multiple online offerings. Typically, behavioral and interest information is stored in cookies or on the servers of providers of tracking technologies (so-called profiling) concerning the online offerings used. This information can then be used, for example, to display advertisements to users that are likely to match their interests.

Controller: The “controller” is the natural or legal person, authority, institution, or other body that, alone or jointly with others, determines the purposes and means of processing personal data.

Processor: “Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

Third Party: A “third party” is any natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

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