Legal Documents

Privacy Policy — memozero Website — memozero

This English version is a non-binding translation of the German “Datenschutzerklärung der memozero Webseite” provided for convenience; in case of any discrepancy, the German version shall prevail.

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to in short as “data”), the purposes for which, and the extent to which we process them in the course of providing our application.

The terms used are not gender-specific.

As of: 7 May 2026

Table of Contents

  • Preamble
  • Controller
  • Overview of Processing Operations
  • Relevant Legal Bases
  • Security Measures
  • Transmission of Personal Data
  • General Information on Data Storage and Erasure
  • Rights of Data Subjects
  • Business Services
  • Payment Procedures
  • Provision of the Online Offering and Web Hosting
  • Web Analytics and Optimization
  • Contact and Inquiry Management
  • Chatbots and Chat Functions
  • Push Notifications
  • Newsletter and Electronic Notifications
  • Promotional Communication via Email, Post, Fax, or Telephone
  • Plug-ins and Embedded Functions and Content
  • Data Protection Information for Whistleblowers
  • Amendment and Update

Controller

Information pursuant to § 5 DDG (German Digital Services Act)

memozero is a service of DK Tech Solutions UG (haftungsbeschränkt) Schwanthalerstr. 141, 80339 Munich, Germany

Authorized representatives: David Schemm & Karsten Kreh

Email address: info(at)memozero.io

Imprint: www.memozero.io/en/legal/imprint/

Overview of Processing Operations

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

  • Master data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of data subjects

  • Service recipients and clients.
  • Employees.
  • Interested parties.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • Third parties.
  • Whistleblowers.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Provision of our online offering and user-friendliness.
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Information technology infrastructure.
  • Whistleblower protection.
  • Sales promotion.
  • Business processes and economic procedures.

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

  • Consent (Art. 6(1)(a) GDPR) - The data subject has given their consent to the processing of personal data relating to them for one specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) - The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests, fundamental rights, and freedoms of the data subject that require the protection of personal data do not override those interests.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability, and separation relating to it. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data, and responses to threats to the data. In addition, we already take the protection of personal data into account during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by privacy-friendly default settings.

Securing online connections via TLS/SSL encryption technology (HTTPS): In order to protect the data of users 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 the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is transmitted securely and in encrypted form.

Transmission of Personal Data

In the course of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or persons. The 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 corresponding contracts or agreements that serve to protect your data with the recipients of your data.

General Information on Data Storage and Erasure

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or no further legal bases for the processing exist. This concerns cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule exist where legal obligations or special interests require a longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and erasure of data that applies specifically to certain processing operations.

Where there are several specifications regarding the retention period or erasure deadlines for a piece of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but rather on the basis of legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and erasure of data: The following general periods 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, as well as the work instructions and other organizational documents necessary for their understanding (§ 147(1)(1) in conjunction with (3) AO, § 14b(1) UStG, § 257(1)(1) in conjunction with (4) HGB).
  • 8 years - Accounting documents, such as invoices and cost receipts (§ 147(1)(4) and (4a) in conjunction with (3) sentence 1 AO as well as § 257(1)(4) in conjunction with (4) HGB).
  • 6 years - Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents, and cash register strips (§ 147(1)(2), (3), (5) in conjunction with (3) AO, § 257(1)(2) and (3) in conjunction with (4) HGB).
  • 3 years - Data required to take into account potential warranty and damages claims or similar contractual claims and rights, as well as to process related inquiries, based on past business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the point in time at which the termination or other ending of the legal relationship takes effect.

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 Art. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is connected with such direct marketing.
  • Right to withdraw consent: You have the right to withdraw 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 obtain access to this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted without delay, 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 data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.

Business Services

We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other performance disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as company organization. Furthermore, we process the data on the basis of our legitimate interests both in proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfillment of legal obligations. Contractual partners are informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g., in online forms, by means of special marking (e.g., colors) or symbols (e.g., asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons of archiving (e.g., for tax purposes, generally ten years). Data disclosed to us by the contractual partner in the context of an order is deleted by us in accordance with the requirements and generally after the end of the order.

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers). Contract data (e.g., subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and economic procedures.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of software and platform services: We process the data of our users, registered users, and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services as well as on the basis of legitimate interests in order to be able to ensure the security of our offering and to develop it further. The required information is marked as such in the context of the order, ordering, or comparable conclusion of contract and includes the information needed for service provision and billing as well as contact information in order to be able to hold any consultations; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Payment Procedures

In the context of contractual and other legal relationships, due to legal obligations, or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, use, in addition to banks and credit institutions, further service providers (collectively “payment service providers”). The payment transactions are carried out, in accordance with the state of the art, exclusively via encrypted connections, so that the data entered is protected from unauthorized access during transmission.

The data processed by the payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs, and checksums, as well as the contract, sum, and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. That is, we do not receive any account- or credit-card-related information, but only information confirming or denying the payment. Under certain circumstances, the data is transmitted by the payment service providers to credit agencies. The purpose of this transmission is identity and creditworthiness checks. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.

The terms and conditions and the privacy notices of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and the assertion of withdrawal, access, and other data subject rights.

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; business and contractual partners. Interested parties.
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Business processes and economic procedures.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).

Provision of the Online Offering and Web Hosting

We process the data of users 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 time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time stamps, 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 erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called a “web host”); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, transmitted data volumes, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure the utilization and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from erasure until the respective incident has been finally clarified.

Web Analytics and Optimization

Web analytics serves to evaluate the visitor flows to our online offering and may include the behavior, interests, or demographic information about visitors as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently. We can likewise determine which areas require optimization.

For reach measurement, we exclusively use a self-hosted and cookieless configuration of the open-source software PostHog. When our website is accessed, usage data is processed exclusively on servers operated by us under the domain core.memozero.io — there is no transmission to third parties (in particular to PostHog Inc.).

The configuration is designed for data minimization:

  • No cookies and no persistent storage in the browser: PostHog is configured with the persistence setting “memory”. Identifiers exist only in the volatile memory of the running browser session; neither cookies nor local storage nor IndexedDB are written. When the page is accessed again or the tab is closed, a new, non-assignable identifier is generated.

  • No cross-device recognition: No cross-device or cross-session tracking takes place.

  • No profiling on the public website: Personal profiles are only created when a user actively identifies themselves with a downstream system (e.g., a customer account at account.memozero.io). No personal profiling takes place on the marketing pages of this website (person_profiles: "identified_only").

  • Types of data processed: Usage data (e.g., page accessed, time spent, click paths, referrer URL, browser type and version, operating system, screen resolution, language). Meta, communication, and procedural data (in particular the IP address — this is technically transmitted to deliver the request and, in the PostHog configuration, is not stored in personal profiles).

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

  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); provision of our online offering and user-friendliness. Security measures.

  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”. Aggregated, non-personally-attributable evaluations (e.g., daily/weekly statistics) may additionally be retained indefinitely.

  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR) — interest in a needs-based design and the statistical evaluation of our online offering. Since the processing uses neither cookies nor comparable storage methods in the user’s end device, consent pursuant to § 25(1) TDDDG is not required.

  • Right to object (opt-out): You can object to the processing at any time by contacting us via the contact channels named in the “Controller” section, or by activating a browser-side “Do Not Track” setting, which we respect.

Further information on processing operations, procedures, and services:

  • PostHog (self-hosted, cookieless): Open-source software for reach measurement; Service provider: Self-operated by DK Tech Solutions UG (haftungsbeschränkt), processing exclusively on infrastructure managed by us under the domain core.memozero.io. There is no transmission to the manufacturer’s cloud (PostHog Inc.); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://posthog.com.

Contact and Inquiry Management

When you contact 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 insofar as this is necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and contributions as well as the information relating to them, such as details on authorship or the time of creation); usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, 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 erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further information on processing operations, procedures, and services:

  • Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data transmitted to us in order to answer and handle the respective matter. This generally includes information such as name, contact information, and, where applicable, further information communicated to us and required for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Chatbots and Chat Functions

As a means of communication, we offer online chats and chatbot functions (collectively referred to as “chat services”). A chat is an online conversation conducted with a certain immediacy. A chatbot is software that answers users’ questions or informs them via messages. When you use our chat functions, we may process your personal data.

If you use our chat services within an online platform, your identification number within the respective platform is additionally stored. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to demonstrate these in accordance with legal requirements.

We point out to users that the respective platform provider can learn that and when users communicate with our chat services, as well as collect technical information about the device used by the users and, depending on their device settings, also location information (so-called metadata) for the purposes of optimizing the respective services and for security purposes. Likewise, the metadata of the communication via chat services (i.e., for example, the information about who communicated with whom) could be used by the respective platform providers, in accordance with their terms, to which we refer for further information, for marketing purposes or to display advertising tailored to users.

If users agree to a chatbot to activate information via regular messages, they have the option at any time to unsubscribe from the information for the future. The chatbot informs users how and with which terms they can unsubscribe from the messages. When the chatbot messages are unsubscribed from, the users’ data is deleted from the directory of message recipients.

We use the aforementioned information to operate our chat services, e.g., to address users personally, to answer their inquiries, to transmit any requested content, and also to improve our chat services (e.g., to “teach” chatbots answers to frequently asked questions).

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and contributions as well as the information relating to them, such as details on authorship or the time of creation). Usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Consent (Art. 6(1)(a) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Push Notifications

With the consent of users, we may send users so-called “push notifications”. These are messages that are displayed on the screens, end devices, or in the browsers of users, even when our online service is not currently being actively used.

In order to register for push notifications, users must confirm the request from their browser or end device to receive the push notifications. This consent process is documented and stored. The storage is necessary in order to recognize whether users have consented to receiving the push notifications and in order to be able to demonstrate the consent. For these purposes, a pseudonymous identifier of the browser (so-called “push token”) or the device ID of an end device is stored.

The push notifications may, on the one hand, be necessary for the fulfillment of contractual obligations (e.g., technical and organizational information relevant to the use of our online offering).

  • Types of data processed: Usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication. Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”. Erasure upon cancellation.
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails, and further electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipients or on the basis of a legal authorization. Insofar as the contents of the newsletter are named in the course of registration for it, these contents are decisive for the consent of the users. For registration for our newsletter, providing your email address is normally sufficient. However, in order to be able to offer you a personalized service, we may ask you to provide your name for a personal address in the newsletter or for further information, if this is necessary for the purpose of the newsletter.

Erasure and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to demonstrate consent previously given. The processing of this data is restricted to the purpose of a potential defense against claims. An individual erasure 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 block list (so-called “blocklist”).

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of demonstrating its proper course. Insofar as we commission a service provider with the dispatch of 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: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved). Usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post).
  • Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Right to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e., withdraw your consents, 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 open and click rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server, or that of the dispatch service provider if we use one, when the newsletter is opened. In the course of this retrieval, technical information, such as details about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until erasure. 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. Legal bases: Consent (Art. 6(1)(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 the legal requirements.

The recipients have the right to withdraw consent given at any time or to object to the promotional communication at any time free of charge via the contact option named above.

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

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers). Content data (e.g., textual or pictorial messages and contributions as well as the information relating to them, such as details on authorship or the time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g., by email or post); marketing. Sales promotion.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Plug-ins 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 be, for example, graphics, videos, or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the user’s IP address, since without the IP address they could not send the content to their browser. The IP address is therefore necessary for the display 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 referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as the 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 the operating system, referring websites, the time of the visit, and further information on the use of our online offering, but may also be combined with such information from other sources.

Information on legal bases: Insofar as we ask users for their consent to the use of the third-party providers, the legal basis for the data processing is the permission. Otherwise, the user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economic, 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 time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, 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 erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on the users’ devices for a period of two years.).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Fonts (provision on our own server): Provision of font files for the purpose of a user-friendly display of our online offering; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Data Protection Information for Whistleblowers

In this section, you will find information about how we handle data of persons who report concerns (whistleblowers), as well as of affected and involved parties, in the context of our whistleblower procedure. Our goal is to provide an uncomplicated and secure way to report possible misconduct by us, our employees, or service providers, in particular 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 the processing is Article 6(1)(c) GDPR and, in the case of special categories of personal data, Art. 9(2)(g) GDPR, § 22 BDSG, in each case in conjunction with § 10 HinSchG. This relates to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the case of the use of the data collected in the reporting procedure, the taking of further investigations or labor-law measures against persons who have been found guilty of a violation.

Insofar as we process data (in particular in the case of established misconduct) in the context of, or in preparation for, legal defense, this is carried out on the basis of our legitimate interests in lawful and ethical conduct pursuant to Art. 6(1)(f) GDPR.

Insofar as you have given us consent to process personal data for specific purposes, the processing is carried out on this basis pursuant to Art. 6(1)(a) GDPR.

Types of data processed: In the course of receiving and processing reports 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 data, and place of residence of the person making the report,
  • Names and data of possible witnesses or persons affected by the report,
  • Names and data of the persons against whom the report is directed,
  • Data about the alleged misconduct,
  • Further relevant details, insofar as communicated by the whistleblower.

For the purposes of investigating the facts and the further procedure, we additionally process the following personal data:

  • Unique identifier of the report,
  • Contact data of the reporting person, if provided,
  • Personal data of persons named in the report, if provided.

Special categories of personal data: It may happen that, in the course of our activities, we collect special types of personal data, in particular when these are communicated by a whistleblower. These include:

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

This data is only processed if it is necessary for this purpose.

Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called “incognito mode” of your browser. This is how you can 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 the browser type and version, the date and time of your access. This also includes the IP address of your end device. This data is temporarily stored 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 the connection of our website. It ensures the security, stability, and functionality of the whistleblower form and is an important component of our measures for ensuring this.

Provision of a name: You have the option of submitting reports anonymously. Insofar as it is not prohibited by national legislation, however, we recommend providing your name and your contact data. This enables us to follow up on the report more effectively and, where applicable, to contact you directly.

If you provide your name and contact data, your identity will be treated strictly confidentially. Exceptions to this confidentiality exist only where we are legally obliged to disclose your identity. This may be necessary in order to safeguard our rights or the rights of our employees, customers, suppliers, or business partners.

Provision of data to third parties: Data related to the reports submitted is only passed on by us to third parties under certain circumstances. This happens either a) when you have given us your express consent to do so, or b) when 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 entitled to examine suspected misconduct and to take necessary measures after an investigation, such as the initiation of disciplinary or court proceedings. Furthermore, service providers carefully selected and monitored by us may receive data for these purposes (for example, the operator of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection provisions in the context of commissioned data processing.

Data retention and erasure: 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 is deleted. In certain situations, however, the data may be retained longer in order to fulfill legal requirements, as long as this is necessary and proportionate.

Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. The incoming reports are processed by authorized persons who are granted access to the respective reports and who carry out the subsequent examination of the facts.

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number); employee data (information on employees and other persons); contact data (e.g., postal and email addresses); content data (e.g., textual or pictorial messages and contributions as well as the information relating to them, such as details on authorship); usage data (e.g., page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions).
  • Data subjects: Employees (e.g., staff, applicants, temporary workers); third parties. Whistleblowers.
  • Purposes of processing: Whistleblower protection.
  • Retention and erasure: Erasure in accordance with the information in the section “General Information on Data Storage and Erasure”.
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Amendment and Update

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