Data protection declaration

Preamble

The following data protection declaration is intended to inform you about the types of personal data (hereinafter also referred to as ‘data’) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offering’).

The terms used are not gender-specific.

As of: 1 November 2024

Controller

E-stahl GmbH
Im Schiffels 29
55491 Büchenbeuren

Authorised representatives: Sven Marx

Email address: info@e-stahl.com

Imprint: https://www.estahl.shop/en/legal/imprint/

Overview of processing

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

Types of data processed

Inventory data.
Employee data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and process data.
Social data.
Image and/or video recordings.
Protocol data.
Performance and behavioural data.
Working hours data.
Salary data.

Special categories of data

Health data.
Religious or ideological beliefs.
Trade union membership.

Categories of data subjects

Beneficiaries and clients.
Employees.
Interested parties.
Communication partners.
Users.
Business and contractual partners.

Purposes of processing

Provision of contractual services and fulfilment of contractual obligations.
Communication.
Security measures.
Reach measurement.
Tracking.
Office and organisational procedures.
Conversion measurement.
Target group formation.
Organisational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and user-friendliness.
Establishment and implementation of employment relationships.
Information technology infrastructure.
Public relations.
Business processes and business management procedures.

Relevant legal bases

Relevant legal bases according to the GDPR: The following is an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Fulfilment of contract and pre-contractual enquiries (Art. 6 (1) (1) (b) GDPR) – the processing is necessary for the fulfilment of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary to fulfil a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) (1) (f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Processing of special categories of personal data concerning health, profession and social security (Art. 9 (2) (h) GDPR) – Processing is necessary for the purposes of preventive medicine or occupational medicine, for the assessment of the employee's ability to work, for medical diagnosis, the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector on the basis of Union law or the law of a Member State or on the basis of a contract with a health professional.

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

Note on the validity of the GDPR and the Swiss DPA: This data protection notice serves to provide information in accordance with both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used for reasons of comprehensibility and because they have a broader geographical application. In particular, the terms ‘processing’ of ‘personal data’, ‘legitimate interest’ and ‘special categories of data’ used in the GDPR are used instead of the terms ‘processing’ of ‘personal data’, ‘predominant interest’ and ‘particularly sensitive personal data’ used in the Swiss DPA. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of the validity of the Swiss DPA.

Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security 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, disclosure, safeguarding of availability and its separation. Furthermore, we have set up procedures to ensure that the rights of data subjects are exercised, that data is deleted and that we respond to data being compromised. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorised access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission over the internet. These technologies encrypt the information that is transmitted between the website or app and the user's browser (or between two servers), thus protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transfers meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signalled by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose it to other departments, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers contracted to carry out IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

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 the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies 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 recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise assured, in particular by standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 (1) GDPR). We will also provide you with the basis for third-country transfers for the individual providers from the third country, with the adequacy decisions taking precedence as the basis. Information on third-country transfers and the relevant adequacy decisions can be found on the European Commission's website: . As part of the so-called ‘Data Privacy Framework’ (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at (in English). We will inform you in the data protection notice which of our service providers are certified under the Data Privacy Framework.

General information on data storage and deletion

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

In particular, data that must be stored for commercial or tax law reasons or that must be stored for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the storage and deletion of data that specifically applies to certain processing operations.

If there is more than one retention period or deletion period for a date, the longest period shall always apply.

If a period does not explicitly begin on a specific date and is at least one year long, it automatically begins 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.

We process data that is no longer needed for the originally intended purpose but is stored due to legal requirements or other reasons exclusively for the reasons that justify its storage.

Further information on processing, procedures and services:

Storage and deletion of data: The following general time limits apply to storage and archiving under German law:
- 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents, accounting vouchers and invoices required for their understanding (Section 147 (3) in conjunction with (1) Nos. 1, 4 and 4a AO, Section 14b (1) UStG, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a AO, Section 257 (1) No. 1 u. 4a 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
- 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labelling, but also wage payroll records, provided they are not already accounting records, and cash register tapes (section 147 (3) in conjunction with (1) nos. 2, 3, 5 AO, section 257 (1) nos. 2 and 3, (4) HGB).
- 3 years – Data required to take into account potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of the data subjects

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

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right of access: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data, as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with the law, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the law.
Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
Complaint to the supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the member state in which you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you are of the opinion that the processing of your personal data is in breach of the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and prospects (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 contractual partners (or pre-contractual), for example to answer inquiries.

We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of breaches of warranty and other breaches of performance. In addition, we use the data to protect our rights and for the purpose of the administrative tasks associated with these obligations, as well as for company organisation. In addition, we process the data on the basis of our legitimate interests in both proper and business management and security measures to protect our contractual partners and our business operations from misuse, endangering their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the limits of the applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners will be informed about further forms of processing, for example for marketing purposes, within the scope of this data protection declaration.

We will notify our contractual partners of the data required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. in principle after four years, unless the data is stored in a customer account, e.g. as long as it has to be kept for legal archiving reasons (usually ten years for tax purposes). We delete data that has been disclosed to us by the contractual partner as part of an order in accordance with the specifications and, in principle, after the end of the order.

Processed data types: inventory 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 e-mail addresses or telephone s); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and time spent on the site, click paths, intensity and frequency of use, types of device and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Recipients and clients; interested parties. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures.
Storage and erasure: Erasure in accordance with the information in the section ‘General information on data storage and erasure’.
Legal basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Comply with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing, procedures and services:

Online shop, order forms, e-commerce and delivery: We process our customers' data in order to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for and deliver them. If necessary for the execution of an order, we use service providers, in particular postal, freight and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such as part of the order or comparable purchase process and includes the information required for delivery or provision and billing, as well as contact information in order to be able to make any necessary inquiries; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).
Contract work: We process the data of our customers and clients (hereinafter uniformly referred to as ‘customers’) in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and deliver or execute or provide them.
The required information is marked as such in the context of the conclusion of the contract, order or comparable contract and includes the information required for delivery and billing, as well as contact information in order to be able to hold any necessary consultations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).

Providers and services used in the course of business activities

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (‘services’) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organisation.

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e. e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as the information concerning them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, duration, customer category).
Data subjects: Service recipients and clients; interested parties; business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other employees).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Business processes and business management procedures.
Storage and deletion: Deletion in accordance with the information in the ‘General information on data storage and deletion’ section.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing, procedures and services:

DATEV: Software for accounting, communication with tax advisors and authorities, and document storage; service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nuremberg, Germany; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website : ; Privacy Policy: . Data processing agreement:Provided by the service provider.

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 the data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other service providers for this purpose (collectively, ‘payment service providers’).

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit reference agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer you to the terms and conditions and the data protection notices of the payment service providers.

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

Processed data types: Inventory 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. contract object, duration, customer category); Usage data (e.g. page views and time spent on the page, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved). Contact data (e.g. postal and e-mail addresses or telephone numbers).
Data subjects: Recipients of services and clients; business and contractual partners. Interested parties.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business management procedures.
Storage and erasure: Erasure in accordance with the information in the section ‘General information on data storage and erasure’.
Legal basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate interests (Article 6 (1) (f) GDPR).

Further information on processing, procedures and services:

Apple Pay: Payment services (technical integration of online payment methods); service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; legal basis: contract fulfilment and pre-contractual requests (Art. 6 (1) (b) GDPR); website: . privacy policy: .
Giropay: payment services (technical integration of online payment methods); service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; legal bases: performance of a contract and prior requests (Article 6 (1) (b) GDPR); website: https://www.giropay.de. Privacy Policy: .
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 basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: . Privacy Policy: .

Provision of online services and web hosting

We process user data in order 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. page views and time spent on the page, click paths, frequency and intensity of use, device types and operating systems used, interactions with content and functions); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, persons involved); protocol data (e.g. log files regarding logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and posts, as well as the information relating to them, such as information on authorship or the time of creation).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Provision of contractual services and fulfilment of contractual obligations.
Storage and erasure: Erasure as described in the section ‘General information on data storage and erasure’.
Legal basis: Legitimate interests (Article 6 (1) (f) GDPR).

Further information on processing, procedures and services:

Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a ‘web host’); legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Collection of access data and log files: Access to our online services is logged in the form of so-called ‘server log files’. The server log files may include the address and name of the accessed websites and files, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been definitively clarified.
Sending and hosting e-mails: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that e-mails are generally not sent in encrypted form over the internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of e-mails between the sender and their receipt on our server; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate Interests (Art. 6 (1) (f) GDPR); Website: https://www.ionos.de; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: .
ecomDATA: web hosting; service provider: ecomDATA GmbH
Steinamangererstraße 9/16
7400 Oberwart
AUSTRIA; website: https://www.ecomdata.de. Privacy policy: https://www.ecomdata.de/datenschutz/.

Use of cookies

The term ‘cookies’ refers to functions that store and read information on users‘ end devices. Cookies can also be used for a variety of purposes, such as to ensure the functionality, security and convenience of online services and to analyse visitor traffic. We use cookies in accordance with legal requirements. To do this, we obtain users’ consent in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of the consent and which cookies are used.

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

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

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device has been closed. This means, for example, that the login status can be stored and preferred content can be displayed directly when the user revisits a website. Likewise, the user data collected using cookies can be used to measure reach. Unless we provide users with explicit information about the type and duration of storage of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to the processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

Processed data types: Meta, communication and process data (e.g. IP addresses, time information, identification numbers, persons involved). Usage data (e.g. page views and time spent on the page, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and user-friendliness.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing, procedures and services:

Processing of cookie data on the basis of consent: We use a consent management solution to obtain users' consent to the use of cookies or to the procedures and providers mentioned in the context of the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this process, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management process. Users also have the option of managing and withdrawing their consent. The declarations of consent are stored in order to avoid having to ask the user again and to be able to provide proof of consent in accordance with legal requirements. The storage is done on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information about the providers of consent management services is available, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of consent (e.g. categories of cookies and/or service providers concerned) and information about the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Cookie opt-out: At the bottom of our website, you will find a link that allows you to change your cookie settings and revoke your consent.

Contact and enquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact information (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as the information concerning them, such as details of authorship or time of creation); usage data (e.g. page views and length of stay, click paths, frequency and intensity of use, types of device and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, persons involved).
Data subjects: Communication partners.
Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
Storage and erasure: Erasure in accordance with the information in the section ‘General information on data storage and erasure’.
Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR). Performance of a contract and prior requests (Art. 6 (1) (1) (b) GDPR).

Further information on processing operations, procedures and services:

Contact form: When you contact us using our contact form, by email or other means of communication, we process the personal data transmitted to us in order to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communicating; legal basis: performance of a contract and prior requests (Art. 6 (1) 1 (b) GDPR), legitimate interests (Art. 6 (1) 1 (f) GDPR).

Web analysis, monitoring and optimisation

Web analysis (also referred to as ‘reach measurement’) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify the times when our online services or their functions or content are most frequently used, or invite reuse. It also enables us to understand which areas require optimisation.

In addition to web analysis, we may also use test procedures to test and optimise different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created and information can be stored in a browser or in a terminal device and then read for these purposes. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have given their consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on the legal basis: If we ask users for their consent to use the third-party providers, the legal basis for data processing is their consent. Otherwise, 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 draw your attention to the information on the use of cookies in this data protection declaration.

Processed data types: Usage data (e.g. page views and duration of visit, click paths, frequency and intensity of use, device types and operating systems used, interactions with content and functions). Meta, communication and process 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: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
Storage and erasure: Erasure in accordance with the information in the ‘General information on data storage and erasure’ section. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing, procedures and services:

Google Analytics: We use Google Analytics to measure and analyse the use of our online services on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a terminal device in order to recognise which content users have accessed within one or more usage processes, which search terms they have used, which they have accessed again or with which they have interacted with our online offer. Likewise, the time of use and its duration are stored, as well as the sources of users who refer to our online offer and technical aspects of their end devices and browsers.
In doing so, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide broad geographic location data by deriving the following metadata from IP addresses: city (and the derived city latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this geolocation data derivation before it is immediately deleted. They are not logged, are not accessible and are not used for any further purposes. When Google Analytics collects measurement data, all IP 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 basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); website: ; security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: ; Data processing agreement: ; Basis for third-country transfers: Data Privacy Framework (DPF ; right to object (opt-out): opt-out plug-in: , settings for the display of advertising: . Further information: (types of processing and processed data).
Google Tag Manager: We use Google Tag Manager, a Google software that allows us to manage website tags centrally through a user interface. Tags are small code elements on our website that are used to record and analyse visitor activity. This technology helps us to improve our website and the content offered on it. The Google Tag Manager itself does not create any user profiles, store cookies with user profiles or carry out any independent analyses. Its function is limited to simplifying and making more efficient the integration and administration of tools and services that we use on our website. Nevertheless, when using the Google Tag Manager, the user's IP address is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this data protection declaration; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); website: https://marketingplatform.google.com; privacy policy: ; data processing agreement:
. Basis for third-country transfers: Data Privacy Framework (DPF).

Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as ‘content’) based on the potential interests of users and the measurement of its effectiveness.

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

In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) for user protection. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, only pseudonyms. This means that we, as well as the providers of the online marketing process, do not know the actual user identity, only the information stored in their profiles.

The statements in the profiles are usually stored in cookies or by similar methods. These cookies can later generally be read on other websites that use the same online marketing method, and they can be analysed for the purpose of displaying content and supplemented with additional data and stored on the server of the online marketing method provider.

In exceptional cases, it is possible to assign clear data to the profiles, especially if, for example, the users are members of a social network that uses our online marketing process and the network links the user profiles with the aforementioned information. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.

We only receive access to summarised information about the success of our advertisements. However, we can use so-called conversion measurements to check which of our online marketing methods have led to a so-called conversion, i.e. for example to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for data processing is permission. Otherwise, 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 draw your attention to the information on the use of cookies in this data protection declaration.

Information on revocation and objection:

We refer to the data protection information of the respective providers and the options for objection (so-called ‘opt-out’) provided by the providers. If no explicit opt-out option has been provided, you have the option of disabling cookies in your browser settings. However, this may restrict the functions of our online services. We therefore recommend the following additional opt-out options, which are offered collectively for each respective area:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: .

c) USA: .

d) Cross-regional: https://optout.aboutads.info.

Processed data types: Usage data (e.g. page views and duration of visit, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time information, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioural profiling, use of cookies); target group formation; marketing; profiles with user-related information (creation of user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
Storage 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 specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Article 6 (1) (a) GDPR). Legitimate interests (Article 6 (1) (f) GDPR).

Further information on processing, procedures and services:

Google Ads and conversion tracking: Online marketing process for the purpose of placing content and ads 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 have a presumed interest in the ads. We also measure the conversion of the ads, i.e. whether users have interacted with the ads and used the advertised offers (so-called conversions). 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 basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR); website:https://marketingplatform.google.com; privacy policy: ; basis for third-country transfers: Data Privacy Framework (DPF); further information: types of processing and processed data: . Data processing terms between controllers and standard contractual clauses for third-country data transfers: .

Presence on social networks (social media)

We maintain an online presence on social networks and process user data in this context in order to communicate with users active on these networks or to provide information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce user rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used to place advertisements inside and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users' computers, in which the usage behaviour and the interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the opt-out options, we refer to the data protection declarations and information provided by the operators of the respective networks.

We would also like to point out that requests for information and the assertion of data subject rights can be most effectively asserted with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. However, if you require assistance, please do not hesitate to contact us.

Processed data types: contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and time spent on the page, click paths, frequency and intensity of use, types of device and operating systems used, interactions with content and functions).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
Storage and erasure: Erasure in accordance with the information in the section ‘General information on data storage and erasure’.
Legal basis: Legitimate interests (Art. 6 (1) (1) (f) GDPR).

Further information on processing, procedures and services:

Facebook Pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not further processing) of data from visitors to our Facebook page (so-called ‘fan page’). This data includes information about the types of content that users view or interact with, or the actions they take (see ‘Things you and others have done and provided’ in the Facebook Data Policy: https://www.facebook.com/privacy/policy /) and information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see ‘Device Information’ in the Facebook Data Policy: ). As explained in the Facebook 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 administrators so that they can understand how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook (‘Information on Page Insights’, ), which specifically governs the security measures that Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, address requests for information or deletion directly to Facebook). The rights of users (in particular with regard to information, deletion, objection and complaints to the relevant supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the ‘Information on Page Insights’ (). The joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transmission of the data to the parent company Meta Platforms, Inc. in the USA; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal basis: Legitimate Interests (Art. 6 (1) (f) GDPR); website: https://www.facebook.com; privacy policy: https://www.facebook.com/privacy/policy/. basis for third-country transfers: Data Privacy Framework (DPF).
YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); privacy policy: ; basis for third-country transfers: Data Privacy Framework (DPF). Right of objection (opt-out): .

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 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 IP address of the user, since they would not be able to send the content to the user's browser without the IP address. The IP address is therefore necessary for the presentation of this content or these functions. We endeavour to use only content from providers who use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. Pixel tags’ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online services, but may also be linked to such information from other sources.

Notes on the legal basis: If we ask users for their consent to use third-party providers, the legal basis for data processing is permission. Otherwise, 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 draw your attention to the information on the use of cookies in this data protection declaration.

Processed data types: Usage data (e.g. page views and time spent on the page, click paths, frequency and intensity of use, device types and operating systems used, interactions with content and functions); Meta, communication and process data (e.g. IP addresses , time stamps, identification numbers, involved persons); inventory data (e.g. full name, home address, contact information, customer number, etc.); contact information (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and posts as well as the information concerning them, such as information on authorship or time of creation).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and user-friendliness.
Storage and erasure: Erasure in accordance with the information in the ‘General information on data storage and erasure’ section. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing, procedures and services:

YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: consent (Art. 6 (1) (a) GDPR); website: https://www.youtube.com; privacy policy: ; basis for third-country transfers: Data Privacy Framework (DPF). Right to object (opt out): Opt-out plug-in: , Settings for the display of advertising: .

Processing of data in the context of employment relationships

In the context of employment relationships, personal data is processed with the aim of effectively establishing, implementing and terminating such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.

The data processing covers various aspects, ranging from the initiation of a contract to its termination. It includes the organisation and administration of daily working hours, the management of access rights and authorisations, as well as the handling of personnel development measures and employee appraisals. The processing also serves the purpose of accounting and the administration of wage and salary payments, which are critical aspects of the execution of the contract.

In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimise operational processes. Furthermore, data processing includes the disclosure of employee data as part of external communication and publication processes where this is necessary for operational or legal purposes.

This data is always processed in compliance with the applicable legal framework, with the aim of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymisation or deletion of data after the processing purpose has been fulfilled or in accordance with legal retention periods.

Processed data types: Employee data (information on employees and other persons in an employment relationship); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data ( e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or pictorial messages and posts as well as the information concerning them, such as information on authorship or time of creation); social data (data subject to the social secret and e.g. processed by social insurance agencies, social welfare agencies or pension authorities); protocol data (e.g. log files regarding logins or the retrieval of data or access times); performance and behavioural data (e.g. performance and behavioural aspects such as performance reviews, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behavioural assessments); working hours data (e.g. e.g. start of working hours, end of working hours, actual working hours, target working hours, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, premiums, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net pay); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and time spent on a page, click paths, frequency and intensity of use, types of device and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
Special categories of personal data: Health data; religious or ideological beliefs. Trade union membership.
Data subjects: Employees (e.g. staff, applicants, temporary staff and other employees).
Purposes of Processing: Establishment and implementation of employment relationships (Processing of employee data in the context of establishing and implementing employment relationships); Business processes and business management procedures; Provision of contractual services and fulfilment of contractual obligations; Public relations; Security measures. Office and organisational procedures.
Legal basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with the law (Article 6 (1) (c) GDPR); Legitimate interests (Article 6 (1) (f) GDPR). Processing of special categories of personal data concerning health, occupation and social security (Art. 9 para. 2 lit. h) GDPR).

Further information on processing operations, procedures and services:

Recording of working hours: Procedures for recording employees' working hours include both manual and automated methods, such as the use of time clocks, time tracking software or mobile apps. Activities such as entering clock-in and clock-out times, break times, overtime and absences are carried out. To check and validate the recorded working hours, they are compared with deployment or shift plans, absences are checked and overtime is approved by superiors. Reports and analyses are created based on the recorded working hours to provide time sheets, overtime reports and absence statistics for management and the HR department; legal basis:contract fulfilment and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Authorisation management: Procedures required to define, manage and control access rights and user roles within a system or organisation (e.g. creation of authorisation profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security guidelines and procedures); legal bases: performance of a contract and prior to entering into a contract (Article 6 (1) (b) GDPR), compliance with a legal obligation (Article 6 (1) (c) GDPR), legitimate interests (Article 6 (1) (f) GDPR).
Special categories of personal data: Special categories of personal data are processed in the context of the employment relationship or to fulfil legal obligations. The special categories of personal data processed include data concerning the health, trade union membership or religious beliefs of employees. This data may be passed on to health insurance companies, for example, or processed to assess the employee's ability to work or for company health management or for information to be provided to the tax office; legal bases: performance of a contract and prior requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Sources of the processed data: Personal data obtained in the context of the application and/or the employment relationship of the employees will be processed. In addition, personal data from other sources will be collected if required by law. These may be tax authorities for tax-related information, the respective health insurance company for information about incapacity to work, third parties such as employment agencies or publicly accessible sources such as professional social networks as part of the application process; legal bases: legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Purposes of data processing: The personal data of employees are primarily processed for the purpose of establishing, implementing and terminating the employment relationship. In addition, the processing of this data is necessary to fulfil legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfil regulatory and supervisory requirements, to optimise electronic data processing and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the purpose of asserting legal claims and for defence in legal disputes; legal bases: performance of a contract and prior requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Transfer of employee data: Employee data is processed internally only by those departments that require it to fulfil operational, contractual and legal obligations.
Data is only transferred to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this may include requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfil his contractual and legal obligations as an employer. These recipients may include: a) banks b) health insurance funds, pension insurance funds, retirement pension funds and other social insurance funds c) authorities, courts (e.g. tax authorities, labour courts, other supervisory authorities within the scope of fulfilling reporting and disclosure requirements) d) Tax and legal advisors e) Third-party debtors in the event of attachment of earnings f) Other bodies to which legally binding declarations must be made.
In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples include information in the sender area of e-mails or letterheads, as well as the creation of profiles on external platforms; legal basis: performance of a contract and prior requests (Art. 6 (1) 1 (b) GDPR), legitimate interests (Art. 6 (1) 1 (f) GDPR).
Transfer of employee data to third countries: Employee data will only be transferred to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), if this is necessary for the fulfilment of the employment relationship, if it is required by law or if employees have given their consent. Insofar as it is legally required, employees will be informed separately about the details; legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).
Business trips and travel expense accounting: Procedures required for planning, executing and settling business trips (e.g. booking trips, organising accommodation and means of transport, managing travel expense advances, submitting and checking travel expense claims, controlling and posting costs incurred, complying with travel policies, handling travel expense management); legal bases: contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Payroll and payroll accounting: Procedures that are necessary for calculating, paying and documenting wages, salaries and other employee benefits (e.g. recording working hours, calculating deductions and surcharges, paying taxes and social security contributions, creating payrolls , keeping payroll records, reporting to the tax office and social insurance agencies); legal bases: contract fulfilment and pre-contractual requests (Art. 6 (1) 1 (b) GDPR), legal obligation (Art. 6 (1) 1 (c) GDPR).
Deletion of employee data: Under German law, employee data is deleted if it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations are observed: Legal basis: Fulfilment of contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data concerning health, occupation and social security (Art. 9 para. 2 lit. h) GDPR).
- General personnel documents – General personnel documents (such as employment contracts, references, additional agreements) are stored for up to three years after the end of the employment relationship (Section 195 BGB).
  Tax-related documents – Tax-related documents in the personnel file are stored for six years (Section 147 AO, Section 257 HGB).
  Information on wages and working hours – Information on wages and working hours for (accident) insurance policyholders with a wage statement is kept for five years (Section 165 I 1, IV 2 SGB VII).
- Salary lists including lists for special payments – Salary lists including lists for special payments, provided that a posting document is available, are kept for ten years (Section 147 AO, Section 257 HGB).
- Wage lists for interim, final and special payments – Wage lists for interim, final and special payments are kept for six years (Section 147 AO, Section 257 HGB).
- Documents on employee insurance – Documents on employee insurance, provided accounting records are available, are kept for ten years (Section 147 AO, Section 257 HGB).
- Contribution statements to social insurance agencies – Contribution statements to social insurance agencies are kept for ten years (Section 165 SGB VII).
  Wage accounts – Wage accounts are kept for six years (Section 41 I 9 EStG).
- Applicant data – This is kept for a maximum of six months from the date of rejection.
- Working time records (if more than 8 hours on weekdays) – These are kept for two years (Section 16 II of the Working Hours Act (ArbZG)).
- Application documents (after online job advertisement) - Are kept for three to a maximum of six months after receipt of the rejection (Section 26
- Federal Data Protection Act (BDSG) n.F., Section 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity to work (AU) - Are kept for up to five years (Section 6 I Expenses Equalisation Act (AAG)).
- Documents on company pension schemes – kept for 30 years (Section 18a of the Act on the Improvement of Company Pension Schemes (BetrAVG)).
- Employees' medical records – kept for twelve months after the onset of the illness if the absences in one year do not exceed six weeks.
- Documents on maternity protection – kept for two years (Section 27 (5) of the Maternity Protection Act (MuSchG)).
Personnel file management: Procedures required for organising, updating and managing employee data and documents (e.g. recording personnel master data, storing employment contracts, references and certificates, updating data when changes occur, compiling documents for employee appraisals, archiving personnel files, complying with data protection regulations); Legal basis: Performance of a contract and prior requests ( Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, occupation and social security (Art. 9 para. 2 lit. h) GDPR).
Personnel development, performance reviews and employee appraisals: Procedures that are necessary in the area of employee development and advancement, as well as in the assessment of their performance and in the context of employee appraisals (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance reviews, conducting target agreement and feedback meetings, career planning and talent management, succession planning); Legal bases: Performance of a contract and prior to entering into a contract inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), processing of special categories of personal data relating to health, occupation and social security (Art. 9 para. 2 lit. h) GDPR).
Obligation to provide data: The controller notifies employees that it is necessary to provide their data. This is generally the case if the data is required for the establishment and execution of the employment relationship or if its collection is required by law. It may also be necessary to provide data if employees assert claims or are entitled to claims. The implementation of these measures or the fulfilment of services depends on the provision of this data (e.g. the provision of data for the purpose of receiving a salary); legal bases: performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers, or if their area of responsibility includes representative functions. It may also be the case if, in the course of performing their duties, they are presented to or communicate with the public, such as in the case of image recordings as part of public relations work. Otherwise, employee data will only be published with their consent or on the basis of the employer's legitimate interests, for example in the case of stage or group photographs taken during a public event; legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).

Amendments and updates

We kindly request that you regularly review the content of our data protection declaration. We will amend the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or any other individual notification.

If we provide addresses and contact information for companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

Definitions

This section provides an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are intended primarily for comprehension.

Employees: Employees are persons who are in an employment relationship, whether as staff, workers or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs his or her work. The employment relationship encompasses various phases, including the establishment of the employment contract, the execution of the contract, during which the employee performs his or her work, and the termination, when the employment relationship ends, whether by resignation, termination agreement or otherwise. Employment data is all information relating 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, holiday entitlement, health data and performance reviews.
Inventory data: Inventory data includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities or systems, enabling clear assignment and communication.
Content Data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
Contact data: Contact data is essential information that enables communication with individuals or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
Conversion tracking: Conversion tracking (also known as ‘visitor action evaluation’) is a process that can be used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
Performance and behavioural data: Performance and behavioural data relates to information about how individuals perform tasks or behave in a particular context, such as in an educational, work or social setting. This data may include metrics such as productivity, efficiency, quality of work, attendance, and adherence to policies or procedures. Behavioural data could include interactions with colleagues, communication styles, decision-making processes, and reactions to various situations. These types of data are often used for performance evaluations, training and development, and decision-making within organisations.
Meta, communication and process data: Meta, communication and process data are categories that contain information about how data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information such as file size, creation date, document author and change histories. Communication data records the exchange of information between users across different channels, such as email traffic, call logs, social network messages and chat histories, including the people involved, timestamps and transmission paths. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
Usage Data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they spend on certain pages and which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and possible problem areas within digital offerings
Personal data: ‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of ‘profiles with user-related information’, or ‘profiles’ for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information demographics, behaviour and interests, such as interaction with websites and their content, etc.) to analyse, evaluate or predict (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. This data typically 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 to analyse system problems, for security monitoring or to create performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offering and may include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, operators of online services can, for example, see at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.
Tracking: ‘Tracking’ is when the behaviour of users can be traced across several online offers. As a rule, information on behaviour and interests with regard to the online offers used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: The ‘controller’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: ‘Processing’ is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
Contract data: Contract data is specific information related to the formalisation of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the parties to the contract and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, pricing arrangements, payment terms, cancellation rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
Payment Data: Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. They include details such as credit card numbers, bank account details, payment amounts, transaction dates, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorisations and fees.
Target group formation: ‘Custom Audiences’ is the term used when target groups are defined for advertising purposes, e.g. to display advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. The term ‘lookalike audiences’ (or similar target groups) is used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. As a rule, cookies and web beacons are used to create custom audiences and lookalike audiences.

Data protection declaration

Preamble

Table of contents

Controller

Overview of processing

Types of data processed

Special categories of data

Categories of data subjects

Purposes of processing

Relevant legal bases

Security measures

Transfer of personal data

International data transfers

General information on data storage and deletion

Rights of the data subjects

Business services

Providers and services used in the course of business activities

Payment procedures

Provision of online services and web hosting

Use of cookies

Contact and enquiry management

Web analysis, monitoring and optimisation

Online marketing

Presence on social networks (social media)

Plug-ins and embedded functions and content

Processing of data in the context of employment relationships

Amendments and updates

Definitions