table of contents

• preamble
• responsible person
• Relevant legal bases
• Overview of processing
• transmission of personal data
• International data transfers
• rights of the data subjects
• Business Services
• Use of online platforms for offer and sales purposes
• Providers and services used in the course of business activities
• Special notes on applications (apps)
• Registration, login and user account
• single sign-on login
• cloud services
• newsletters and electronic notifications
• Advertising communication via email, post, fax or telephone
• Presences in social networks (social media)
• Plugins and embedded functions and content
• Change and update of the privacy policy
• definitions of terms
  

responsible person

wobie GmbH

An der Alster 6

20099 Hamburg

Germany

4940 237 24 33 312

Authorized representatives:

Karsten Fröiland

E-mail address:

kontakt@wobie.de

Imprint:

www.wobie.de/imprint

Relevant legal bases

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 regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

• Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
• Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
• Legal obligation (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
• Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains in particular special regulations on the right to information, the right to deletion, the right of objection, 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. In addition, state data protection laws of the individual federal states may apply.

Note on the validity of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "personal data requiring particular protection" used in the Swiss DSG, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the validity of the Swiss DSG.

Overview of processing

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

types of data processed

• inventory data.
• payment details.
• contact details.
• content data.
• contract data.
• usage data.
• Meta-, communication- and procedural data.
• Event data (Facebook).

categories of data subjects

• Customers.
• employees.
• interested parties.
• communication partner.
• users.
• business and contractual partners.

purposes of processing

• Provision of contractual services and fulfillment of contractual obligations.
• contact requests and communication.
• security measures.
• direct marketing.
• reach measurement.
• office and organizational procedures.
• conversion measurement.
• Managing and responding to inquiries.
• feedback.
• Marketing.
• Profiles with user-related information.
• registration process.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.

transmission of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. 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 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 if 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 be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transmission (Art. 49 Para. 1 GDPR). Furthermore, we will inform you of the basis for third-country transfers from the individual providers from the third country, with the adequacy decisions taking priority as the basis. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In the privacy policy we will inform you which service providers we use are certified under the Data Privacy Framework.

rights of the data subjects

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

• Right to object: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
• Right to withdraw consent: You have the right to withdraw consent at any time.
• Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
• Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
• Complaint to a 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 habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes 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") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical 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. 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 framework of 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 are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.

We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after statutory warranty and similar obligations have expired, i.e., generally after 4 years, unless the data is saved in a customer account, e.g. as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant for tax purposes as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent, or the accounting document was created, the recording was made or the other documents were created.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.

• Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
• Affected persons: customers, interested parties, business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Administration and response to inquiries.
• Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

• Customer account: Customers can create an account within our online offering (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we save the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is kept for purposes other than making it available in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when terminating the customer account; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).

Use of online platforms for offer and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the methods used on the platforms for range measurement and interest-based marketing.

• Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
• Data subjects: Customers.
• Purposes of processing: Provision of contractual services and customer service; marketing.
• Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

• Amazon: online marketplace for e-commerce; service provider: Amazon EU S.à rl (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.amazon.de/; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.

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" for short) in compliance with legal requirements. Their use is based on our interest in the proper, lawful and economical management of our business operations and our internal organization.

• Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms). Contract data (e.g. subject of the contract, term, customer category).
• Affected persons: customers; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
• Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

• TuneIn: TuneIn is an online service and mobile app for Android, Apple iOS, Blackberry, Microsoft Windows Phone, Fire OS and Samsung that enables streaming of radio stations and Internet radio; Service provider: TuneIn, Inc.
• Spotify: Spotify (from English to spot and to identify) is a listed audio streaming service based in Stockholm. In addition to music, audio books and podcasts can also be streamed; service provider: Spotify AB.

Special notes on applications (apps)

We process the data of the users of our application to the extent that this is necessary in order to provide the application and its functionalities to the users, to monitor its security and to develop it further. We can also contact users in compliance with the legal requirements if communication is necessary for the purposes of administration or use of the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this data protection declaration.

Legal basis: The processing of data required to provide the functionality of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. approval of device functions). If the processing of data is not required to provide the functionality of the application, but serves the security of the application or our business interests (e.g. collection of data for the purposes of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

• Types of data processed: Inventory data (e.g. names, addresses); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); payment data (e.g. bank details, invoices, payment history). Contract data (e.g. subject of the contract, term, customer category).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
• Legal basis:
• Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR). Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

• Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our application and to be able to develop it further. The required information is marked as such in the context of the use, order, purchase or comparable contract conclusion and can include the information required for the provision of services and for any billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
• Storage of a universal and unique identifier (UUID):
  The application stores a so-called universally unique identifier (UUID) for the purposes of analyzing the use and functionality of the application and storing user settings. This identifier is generated when this application is installed (but is not linked to the device, so it is not a device identifier in this sense), remains stored between the start of the application and its updates, and is deleted when users remove the application from their device.

Registration, login and user account

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

When you use our registration and login functions and the user account, we save the IP address and the time of the respective user action. The data is saved on the basis of our legitimate interests and those of the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

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

• Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; administration and response to inquiries. Provision of our online offer and user-friendliness.
• Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, methods and services:

• Registration with pseudonyms: Users may use pseudonyms as user names instead of real names; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

single sign-on login

"Single sign-on" or "single sign-on registration or authentication" refers to procedures that allow users to log in to a provider of single sign-on procedures (e.g. a social network), including our online offering, using a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via a button.

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

Users are asked to note that the information we store about them can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually happens. If, for example, users' email addresses change, they must change them manually in their user account with us.

We can use single sign-on registration, if agreed with the users, as part of or before the fulfillment of the contract, if the users have been asked to do so, process it within the scope of consent and otherwise use it on the basis of our legitimate interests and the interests of the users in an effective and secure registration system.

If users decide that they no longer want to use the link between their user account and the single sign-on provider for the single sign-on process, they must cancel this connection within their user account with the single sign-on provider. If users want to delete their data from us, they must cancel their registration with us.



• Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); Event data (Facebook) ("Event data" is data that we can transmit to Facebook, for example via Facebook pixel (via apps or other means) and that relates to people or their actions. The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences). Event data does not contain the actual content (such as comments written), login information, or contact information (i.e. no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it when our Facebook account is deleted).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures. Registration procedures.
• Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).







Further information on processing procedures, methods and services:

• Apple Single-Sign-On: Authentication service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
• Facebook Single-Sign-On: Authentication service of the Facebook platform; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Standard contractual clauses (ensuring data protection level when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
• Google Single-Sign-On: Authentication service; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Opt-out option: Settings for the display of advertisements: https://adssettings.google.com/authenticated; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Website: https://www.google.de; Privacy Policy: https://policies.google.com/privacy.
• Spotify: Spotify - music hosting and widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.spotify.com/de; Privacy Policy: https://www.spotify.com/de/legal/privacy-policy/.

Cloud Services

newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.

Contents:

Information about us, our services, promotions and offers.

• Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
• Data subjects: communication partners.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
• Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

• Measuring opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected.
  
  This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users.
  
  The measurement of opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the user’s consent.
  
  Unfortunately, it is not possible to revoke the performance measurement separately. In this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted;
  Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
  

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke consent given or to object to advertising communication at any time.



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

• Types of data processed: Inventory data (e.g. names, addresses). Contact data (e.g. email, telephone numbers).
• Data subjects: communication partners.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Presences in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer 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 it could, for example, make it more difficult to enforce user rights.

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

For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

• Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://instagram.com/about/legal/privacy.
• Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of 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 do and provide" in the Facebook data policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/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, called "Page Insights", to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_dataThe joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

Plugins and embedded functions and content

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

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

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offer and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures). Profiles with user-related information (creation of user profiles).
• Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

• Spotify: Spotify - music hosting and widget; Service provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.spotify.com/de. Privacy Policy: https://www.spotify.com/de/legal/privacy-policy/.
• TuneIn: TuneIn is an online service and mobile app for Android, Apple iOS, Blackberry, Microsoft Windows Phone, Fire OS and Samsung that enables streaming of radio stations and Internet radio; Service provider: TuneIn, Inc.
• Notes on fonts used: Only Google Fonts are used (https://fonts.google.com/).

Change and update of the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt 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 your cooperation (e.g. consent) or other individual notification.



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

definitions of terms

This section provides you with an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

• Conversion measurement: Conversion measurement (also known as "visit 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 allows us to see whether the ads we have placed on other websites were successful.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more special characteristics that express 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 in using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
• Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing 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 covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.