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PRIVACY POLICY

Präambel

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all 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 services").

The terms used are not gender-specific.

As of October 13, 2025

Responsible

Martyna Grabowska
Ginkgo Interiors
Himbselstraße 3
82319 Starnberg

Authorized representative: Martyna Grabowska

Email address: martyna@ginkgointeriors.com

Overview of processing activities

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

Types of data processed

  • Inventory data.

  • Payment details.

  • Contact details.

  • Content data.

  • Contract details.

  • Usage data.

  • Metadata, communication data and process data.

  • Log data.

Categories of affected persons

  • Recipient of services and client.

  • Interested parties.

  • Communication partner.

  • Users.

  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.

  • Communication.

  • Security measures.

  • Direct marketing.

  • Office and organizational procedures.

  • Organizational and administrative procedures.

  • Feedback.

  • Provision of our online services and user-friendliness.

  • Information technology infrastructure.

  • Public relations.

  • Business processes and business management procedures.

Relevant legal bases

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

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  • Contractual performance and pre-contractual inquiries (Art. 6 para. 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 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) - The processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Notice regarding the applicability of the GDPR and Swiss Federal Act on Data Protection (FADP): This privacy notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). Therefore, please note that, due to its broader geographical scope and clarity, the terms used are those of the GDPR. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "special categories of personal data" used in the Swiss FADP, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are employed. However, the legal meaning of these terms remains consistent with the applicability of the Swiss FADP.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

IP address truncation: If IP addresses are processed by us or by the service providers and technologies we use, and processing a full IP address is not necessary, the IP address is truncated (also known as "IP masking"). This involves removing the last two digits, or the last part of the IP address after a period, or replacing them with placeholders. The purpose of truncating the IP address is to prevent or significantly hinder the identification of a person based on their IP address.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thus protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to 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 this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure its protection.

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business interests or is necessary for the fulfillment of our contractual obligations, or if the data subject has given consent or if there is a legal basis for doing so.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: The Data Protection Framework (DPF) forms the primary layer of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

For each service provider, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

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

General information on data storage and deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

In cases where multiple retention periods or deletion deadlines for a given date are specified, the longest period always applies. Data that is no longer retained for its originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Data retention and deletion: The following general retention periods apply to data 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 organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).

  • 8 years - accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).

  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).

  • 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of data subjects

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

  • Right to object: You have the right to object, 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 of withdrawal for consents: You have the right to withdraw any consent you have given at any time.

  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.

  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.

  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, in accordance with the legal requirements, or to request its transmission to another controller.

  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), within the framework of contractual and similar legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfill our contractual obligations. These include, in particular, the obligation to provide the agreed services, any update obligations, and remedying warranty claims and other service disruptions. Furthermore, we use the data to protect our rights and for the administrative tasks associated with these obligations, as well as for company organization. We also process the data based on our legitimate interests in both proper and efficient business management and security measures to protect our contractual partners and our business operations from misuse, compromise of their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Within the framework of applicable law, we only disclose contractual partner data to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, such as for marketing purposes, within the scope of this privacy policy.

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

We delete data after the expiry of statutory warranty periods and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (for example, for tax purposes, usually ten years). Data disclosed to us by the contractual partner within the scope of a contract is deleted according to the specifications and generally after the contract has ended.

  • Types of data processed: 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 email addresses or telephone numbers); contract data (e.g., subject matter of the contract, term, customer category).

  • Affected persons: Service recipients and clients; interested parties; business and contractual partners.

  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and management procedures.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Contract performance and pre-contractual 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).

Further information on processing procedures, methods and services:

  • Agency services: We process our clients' data within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Provision of the online service and web hosting

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

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved); log data (e.g., log files concerning logins or data retrieval or access times); content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date).

  • Affected persons: 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 equipment (computers, servers, etc.)). Security measures.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

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

Further information on processing procedures, methods and services:

  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files." Server log files may contain the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and 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 anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.

  • Email sending and hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

  • Wix: Hosting and software for creating, providing, and operating websites, blogs, and other online services; Service provider: Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://de.wix.com/ ; Privacy policy: https://de.wix.com/about/privacy ; Data processing agreement: https://www.wix.com/about/privacy-dpa-users . Basis for third-country transfers: Data Privacy Framework (DPF).

Use of cookies

The term “cookies” refers to functions that store information on users’ devices and read it back. Cookies can serve various purposes, such as ensuring functionality, security, and convenience of online services, as well as analyzing visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions, such as saving settings or ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We clearly inform users about the scope of data processing and which cookies are used.

Legal basis for data processing:
Whether we process personal data via cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as described above and in the context of each service and procedure.

Storage duration:
Cookies are generally classified as follows:

  • Temporary cookies (session cookies): Deleted at the latest after a user leaves the website and closes their device (e.g., browser or mobile application).

  • Permanent cookies: Remain stored even after closing the device. For example, login status can be saved, and preferred content can be displayed automatically when a user revisits a website. Cookies may also be used to measure reach and user behavior. If we do not provide specific information about the type and duration of cookies (e.g., during consent collection), users should assume that they are permanent, with storage lasting up to two years.

General information on withdrawal and objection (opt-out):
Users can withdraw their consent at any time and object to processing according to legal requirements, including via their browser privacy settings.

Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).

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

Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Consent (Art. 6(1)(a) GDPR).

Further information on processing, procedures, and services:

Processing cookie data based on consent:
We use a consent management solution to obtain users’ consent for the use of cookies and the procedures and providers specified within the system. This process collects, records, manages, and allows withdrawal of consent, particularly regarding cookies and similar technologies used to store, read, and process information on users’ devices.

Within this process, users provide consent for cookie usage and associated data processing, including the specific processing and providers listed in the consent management procedure. Users can manage and withdraw consent at any time. Consent records are stored to avoid repeated requests and to demonstrate compliance with legal requirements. Storage occurs server-side and/or via a cookie (so-called opt-in cookie) or similar technology, linking consent to a specific user or device.

General information (if provider details are not specified):
Consent is stored for up to two years. A pseudonymous user identifier is created, along with the timestamp of consent, the scope of consent (e.g., categories of cookies and/or service providers), and information about the browser, system, and device used.
Legal basis: Consent (Art. 6(1)(a) GDPR).

Blogs and publication media

We use blogs or similar online communication and publication tools (hereinafter referred to as "publication medium"). Reader data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. For further information regarding the processing of visitor data to our publication medium, please refer to the privacy policy.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).

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

  • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online services and user-friendliness; security measures; organizational and administrative procedures.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

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

Further information on processing procedures, methods and services:

  • Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves could be held liable for the comment or post and are therefore interested in the author's identity.

    Furthermore, we reserve the right to process user data for spam detection purposes based on our legitimate interests.

    On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting.

    The personal information provided in the comments and posts, including contact details, website information, and content, will be stored by us permanently until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Contact and inquiry management

When you contact us (e.g., by mail, contact form, email, phone, or via social media) or within the context of existing user or business relationships, the information you provide is processed to the extent necessary to respond to your inquiries and any requested actions.

Types of data processed:

  • Master data (e.g., full name, address, contact details, customer number)

  • Contact data (e.g., postal and email addresses, phone numbers)

  • Content data (e.g., text or image messages and posts, including metadata such as authorship or creation date)

  • Usage data (e.g., page views, time spent on pages, click paths, frequency and intensity of use, device types and operating systems, interactions with content and features)

  • Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved parties)

Data subjects: Communication partners.

Purposes of processing:

  • Communication

  • Organizational and administrative procedures

  • Feedback (e.g., collecting feedback via online forms)

  • Provision of our online services and user-friendliness

Storage and deletion: Data will be deleted in accordance with the section “General information on data storage and deletion”.

Legal basis:

  • Legitimate interests (Art. 6(1)(f) GDPR)

  • Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR)

Contact Forms
When you contact us via a contact form, email, or other communication channels, we process the personal data you provide to respond to and handle your request. This typically includes your name, contact information, and any other relevant information necessary for proper handling. Data is used solely for the purpose of communication and responding to inquiries.
Legal basis: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR)

Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (“Newsletters”) only with recipients’ consent or on a legal basis. If newsletter content is mentioned during sign-up, it forms the basis of user consent. Typically, an email address is sufficient for registration. Additional information, such as your name, may be requested for personalized communication if necessary for the newsletter’s purpose.

Deletion and processing limitations:
Opted-out email addresses may be stored for up to three years based on legitimate interests, to document previously given consent. Data processing is limited to defending potential claims. Users can request deletion at any time. Where legally required to retain objections, email addresses may be stored on a blocklist solely for that purpose.

Logging and service providers:
The newsletter sign-up process is logged based on our legitimate interests to verify proper procedure. If we use a service provider for sending emails, this is also based on our legitimate interests in efficient and secure delivery.

Content:
Information about us, our services, promotions, and offers.

Types of data processed:

  • Master data (e.g., name, address, contact details, customer number)

  • Contact data (e.g., postal/email addresses, phone numbers)

  • Meta, communication, and procedural data (e.g., IP addresses, timestamps, ID numbers, involved persons)

  • Usage data (e.g., page views, time spent, click paths, usage intensity, device types, operating systems, interactions with content and features)

Data subjects: Communication partners

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

Legal basis: Consent (Art. 6(1)(a) GDPR)

Opt-out:
You can unsubscribe from newsletters at any time, withdrawing consent or objecting to further communications. A link to unsubscribe is provided at the end of each newsletter, or you can use the contact options listed above, preferably email.

Tracking Open and Click Rates:
Newsletters may contain “web beacons” — tiny files retrieved from our servers (or those of our provider) when the newsletter is opened. This collects technical information (e.g., browser, system) as well as IP address and timestamp. Data is used to improve newsletter performance, understand reading behavior, and tailor content to recipients’ interests. Open and click rates are stored in user profiles until deletion. Analysis helps us optimize content and segment newsletters according to user preferences.
Legal basis: Consent (Art. 6(1)(a) GDPR)

Presences in social networks (social media)

We maintain online presences on social networks and process user data to communicate with active users or provide information about us.

Please note that user data may be processed outside the European Union. This may involve risks for users, such as limitations in enforcing their rights.

User data on social networks is generally also processed for market research and advertising purposes. For example, usage profiles may be created based on user behavior and interests. These profiles can be used to display targeted ads both within and outside the platforms. Cookies are typically stored on users’ devices to record behavior and interests. Usage profiles may also include data independent of the devices used by users (especially if they are logged into the platforms).

For detailed information about processing methods and opt-out options, we refer to the privacy policies of the respective networks.

For data subject requests or exercising rights, it is most effective to contact the platform directly, as only they have access to the data and can take action or provide information. If needed, you may contact us for assistance.

Types of data processed:

  • Contact data (e.g., postal/email addresses, phone numbers)

  • Content data (e.g., text or image messages, including authorship and timestamps)

  • Usage data (e.g., page views, time on site, click paths, frequency of use, device types, operating systems, interactions with content and features)

Data subjects: Users (e.g., website visitors, online service users)

Purposes of processing: Communication; feedback (e.g., via online forms); public relations

Storage and deletion: Deleted according to “General information on data storage and deletion”

Legal basis: Legitimate interests (Art. 6(1)(f) GDPR)

Social Media Platforms

  • Instagram: Allows sharing photos and videos, commenting, liking, messaging, and following profiles/pages. 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.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/. Cross-border transfers: Data Privacy Framework (DPF).

  • Facebook Pages: Profiles within Facebook. Meta Platforms Ireland Limited is jointly responsible with us for collecting and transmitting data from visitors to our Facebook page. Data may include usage behavior (e.g., viewed or interacted content, actions taken) and device information (IP address, operating system, browser type, language, cookies). Facebook also provides analytics via “Page Insights” based on this data. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Website: https://www.facebook.com. Privacy Policy: https://www.facebook.com/privacy/policy/. Cross-border transfers: Data Privacy Framework (DPF), Standard Contractual Clauses.

  • LinkedIn: Jointly responsible with LinkedIn Ireland Unlimited Company for data collection used to generate “Page Insights” (statistics) for our LinkedIn profiles. Data includes types of content viewed, interactions, actions taken, device information (IP, OS, browser, language, cookies), and profile information (job function, country, industry, hierarchy, company size, employment status). Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Website: https://www.linkedin.com. Privacy Policy: https://www.linkedin.com/legal/privacy-policy. Cross-border transfers: Data Privacy Framework (DPF), Standard Contractual Clauses. Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

  • Pinterest: Allows sharing, commenting, liking, curating posts, messaging, and following profiles. Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.

Definitions of terms

This section provides an overview of the terminology used in this privacy policy. Where terms are legally defined, the legal definitions apply. The explanations below are primarily intended to aid understanding.

  • Master Data: Master data includes essential information necessary for identifying and managing contractual partners, user accounts, profiles, and similar assignments. This can include personal and demographic information such as names, contact details (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (e.g., user IDs). Master data forms the basis for any formal interaction between individuals and services, systems, or institutions, enabling clear identification and communication.

  • Content Data: Content data includes information generated in the creation, editing, and publication of all types of content. This category can include text, images, videos, audio files, and other multimedia content published across platforms and media. Content data also includes metadata, such as tags, descriptions, authorship information, and publication dates.

  • Contact Data: Contact data is essential information that enables communication with individuals or organizations. It includes phone numbers, postal addresses, email addresses, social media handles, and instant messaging identifiers.

  • Meta, Communication, and Process Data: These categories include information about how data is processed, transmitted, and managed. Meta data (“data about data”) describes context, origin, and structure of other data, such as file size, creation date, document author, and change history. Communication data captures the exchange of information between users via email, calls, social media messages, or chats, including participants, timestamps, and transmission methods. Process data describes workflows and operations within systems or organizations, including transaction logs, activity records, and audit trails for tracking and verification purposes.

  • Usage Data: Usage data captures how users interact with digital products, services, or platforms. This includes which functions are used, time spent on pages, navigation paths, usage frequency, timestamps, IP addresses, device information, and location data. Usage data is valuable for analyzing user behavior, optimizing user experiences, personalizing content, improving products, and identifying trends or potential issues.

  • Personal Data: Personal data is any information relating to an identified or identifiable natural person (the “data subject”). A person is considered identifiable if they can be identified directly or indirectly, for example, by name, identification number, location data, online identifier (e.g., cookie), or one or more unique characteristics reflecting physical, physiological, genetic, mental, economic, cultural, or social identity.

  • Log Data: Log data is information about events or activities recorded within a system or network. This typically includes timestamps, IP addresses, user actions, error messages, and other system usage details. Log data is often used for system analysis, security monitoring, or performance reporting.

  • Controller: The “controller” is the natural or legal person, authority, organization, or entity that alone or jointly determines the purposes and means of processing personal data.

  • Processing: “Processing” is any operation performed on personal data, with or without automated means. This includes collecting, evaluating, storing, transmitting, or deleting data.

  • Contract Data: Contract data refers to information related to formal agreements between two or more parties. It documents terms under which services or products are provided, exchanged, or sold. This category includes identification of contractual parties, start and end dates, service or product details, pricing, payment terms, cancellation rights, renewal options, and special clauses. Contract data serves as the legal basis for relationships between parties, clarifying rights and obligations, enforcing claims, and resolving disputes.

  • Payment Data: Payment data includes all information required to process financial transactions between buyers and sellers. This may include credit card numbers, bank account information, transaction amounts, dates, verification numbers, and billing information. Payment data may also include payment status, chargebacks, authorizations, and fees.

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