PRIVACY POLICY

Preamble

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

The terms used are not gender-specific.

Status: September 19, 2025

Table of Contents

Controller

Nils Arbes
Budapester Straße 37
20359 Hamburg

Email address: nils.arbes@googlemail.com

Overview of Processing

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.
  • Employee data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication and procedural data.

Categories of Data Subjects

  • Employees.
  • Communication partners.
  • Users.
  • Third parties.
  • Whistleblowers.

Purposes of Processing

  • Communication.
  • Reach measurement.
  • Tracking.
  • Audience formation.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Whistleblower protection.
  • Public relations.

Relevant Legal Bases

Relevant legal bases according to GDPR: Below you will find 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 regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant 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 their personal data for one or more specific purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - 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 data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

The 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, input, disclosure, ensuring availability, and separation concerning them. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data during the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to other entities, companies, legally independent organizational units, or persons, or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

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 the use of third-party services or disclosure or transfer of data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with 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 dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguarding ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of any political or legal changes.

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

For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, express consent, or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: 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 provisions as soon as the underlying consent is revoked or there are no further legal bases for processing. This applies to cases in which the original processing purpose ceases to apply 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 to protect the rights of other natural or legal persons must be archived accordingly.

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

If multiple retention periods or deletion deadlines are specified for a piece of data, the longest period always applies. Data that is no longer retained for the originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

Storage and deletion of data: The following general periods apply to storage and archiving according to 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 records, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with 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, operating accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting records and cash register receipts (§ 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 compensation claims or similar contractual claims and rights and to process related inquiries, based on previous business experience and usual industry practices, are 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 data subjects under the GDPR, you have various rights, which result in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent given at any time.
  • Right to information: You have the right to request confirmation as to whether relevant data is being processed and to receive information about 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 data concerning you or the rectification of incorrect 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 deleted immediately, or alternatively, in accordance with legal requirements, to request restriction of processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Contact and Inquiry Management

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

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

  • Contact form: When contacting us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to answer and process the respective concern. This typically includes information such as name, contact information, and, if applicable, further information that is communicated to us and required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Presence on Social Networks (Social Media)

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

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

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

For a detailed presentation of the respective forms of processing and the opt-out options, we refer to the privacy statements 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 also point out that these can be asserted most effectively with the providers. Only the latter have access to user data in each case and can take appropriate measures directly and provide information. Should you still need assistance, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts as well as information concerning them, such as information on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, 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: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Instagram: Social network, allows sharing of photos and videos, commenting and favoriting posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offer 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").

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

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • 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); Tracking (e.g., interest/behavior-based profiling, use of cookies); Audience formation; Marketing. Profiles with user-related information (creation of user profiles).
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion". 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).
  • Legal bases: 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 processes, procedures and services:

  • Instagram plugins and content: Instagram plugins and content - This may include content such as images, videos or texts and buttons with which users can share content from this online offer within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects or receives in the context of a transmission by means of Instagram functions (e.g., embedding functions for content) that are executed on our online offer for the following purposes: a) Display of content and advertising information that correspond to the presumed interests of users; b) Delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improvement of recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous for us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum", https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

Privacy Information for Whistleblowers

In this section you will find information about how we handle data from persons who provide information (whistleblowers) as well as from affected and involved parties in the context of our whistleblower procedure. Our goal is to provide an uncomplicated and secure way to report possible misconduct by us, our employees or service providers, especially for actions that violate laws or - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Legal bases (Germany): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 para. 1 sentence 1 lit. c) GDPR and in the case of special categories of personal data Art. 9 para. 2 lit. g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the case of use of the data collected in the reporting procedure, taking further investigations or employment law measures against persons who have been convicted of a violation.

Insofar as we process data (especially in the case of established misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in legal and ethical conduct in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

Insofar as you have given us consent to process personal data for certain purposes, processing is carried out on this basis in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and in the case of special - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Legal bases (Austria): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HSchG), the legal basis for processing is Article 6 para. 1 sentence 1 lit. c) GDPR and in the case of special categories of personal data Art. 9 para. 2 lit. g) GDPR, each in conjunction with § 8 HSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the case of use of the data collected in the reporting procedure, taking further investigations or employment law measures against persons who have been convicted of a violation.

Insofar as we process data (especially in the case of established misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in legal and ethical conduct in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

Insofar as you have given us consent to process personal data for certain purposes, processing is carried out on this basis in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and in the case of special categories - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext ); Employee data (information about employees and other persons in a - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext ); Contact data (e.g., postal and email addresses or - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext ); Content data (e.g., textual or pictorial messages and posts as well as information concerning them, such as information on authorship - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ). Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext ).
  • Data subjects: Employees (e.g., employees, applicants, temporary workers and other - This text section must be unlocked with a premium license. - premiumtext premiumtext premiumtext ); Third parties. Whistleblowers.
  • Purposes of processing: Whistleblower protection.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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