Privacy Policy

Preamble

With the following Privacy Policy, we wish to inform you about the types of your personal data (hereinafter also briefly referred to as "data") 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 offering").

The terms used are not gender-specific.

As of: August 5, 2025

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Relevant Legal Bases
• Security Measures
• Transfer of Personal Data
• International Data Transfers
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Business Services
• Provision of the Online Offering and Web Hosting
• Use of Cookies
• Blogs and Publication Media
• Contact and Inquiry Management
• Communication via Messenger
• Newsletter and Electronic Notifications
• Customer Reviews and Evaluation Procedures
• Presences in Social Networks (Social Media)
• Plug-ins and Embedded Features and Content

Controller

Price Management Institute GmbH
Managing Director: Dr. Markus Husemann-Kopetzky

Pater-Rupert-Mayer-Str. 38a
82049 Pullach

Authorized Representatives: Dr. Markus Husemann-Kopetzky

E-Mail-Adresse: mhk@local.gress-marketing.de

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 concerned.

Types of Data Processed

• Inventory data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication, and process data.
• Log data.

Categories of Data Subjects

• Service recipients and clients.
• Interested parties.
• Communication partners.
• Users.
• Business and contractual partners.
• Education and course participants.

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Direct marketing.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Feedback.
• Marketing.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Public relations.
• Business processes and commercial procedures.

Relevant Legal Bases

Relevant Legal Bases under the 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 GDPR regulations, national data protection requirements may apply in your or our country of residence or establishment. 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 their consent to the processing of personal data concerning them for one or more specific purposes.
• Performance of a contract 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 Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains special regulations regarding the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated individual decision-making, including profiling. Furthermore, the state data protection laws of the individual federal states may apply.

Note on the applicability of GDPR and Swiss DPA: These data protection notices serve to provide information both under the Swiss DPA and under the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader territorial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data", "overriding interest", and "particularly sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest", and "special categories of data" used in the GDPR are employed. However, the legal meaning of the terms will continue to be determined according to the Swiss DPA within the scope of its applicability.

Security Measures

In accordance with legal requirements and 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 risk 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, input, disclosure, ensuring availability, and separation concerning them. Furthermore, we have established procedures that ensure 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 or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

Securing Online Connections with TLS/SSL Encryption Technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt information transferred between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

In the course of our processing of personal data, it may occur that this data is transferred to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with 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 using third-party services or disclosing/transferring data to other persons, entities, or companies (which can be identified by the postal address of the respective provider or if the Privacy Policy explicitly refers to data transfer to third countries), this is always done in compliance 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 on July 10, 2023. Additionally, 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 DPF forms the primary layer of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur within the DPF, the Standard Contractual Clauses will act as a reliable fallback option. This way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For individual service providers, we will 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 U.S. 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, explicit consents, 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 consents are revoked or no further legal bases for processing exist. This applies to cases where the original processing purpose ceases to apply or the data is no longer required. 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 data protection notices contain additional information on the retention and deletion of data that specifically applies to certain processing activities.

If there are multiple indications regarding the retention period or deletion deadlines for data, the longest period is always decisive. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons will be processed by us exclusively for the reasons justifying its retention.

Retention and Deletion of Data: The following general periods apply to retention and archiving under German law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents 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 vouchers, such as invoices and expense 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, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., timesheets, cost accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting vouchers, and cash register strips (§ 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, as well as to process related inquiries, based on previous business experience and common 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 data subjects, you have various rights under the GDPR, which arise in particular from Art. 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 Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these 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; 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 given consents at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
• Right to rectification: You have the right, in accordance with legal requirements, to demand the completion of incomplete personal data concerning you or the rectification of inaccurate personal data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that personal data concerning you be erased without undue delay, or, alternatively, to demand a restriction of the processing of the data in accordance with legal requirements.
• Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.
• 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, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Business Services

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

We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations, and remedies for warranty and other performance disruptions. Furthermore, we use the data to safeguard our rights and for administrative tasks associated with these obligations, as well as for corporate organization. We also process the data based on our legitimate interests in both proper and economically sound business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunication, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). Within the framework of applicable law, we only disclose data of contractual partners to third parties insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, such as for marketing purposes, within the scope of this Privacy Policy.

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

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

• Processed data types: Inventory data (e.g. the full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and e-mail addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
• Affected persons: service recipients and clients; prospective customers; business and contractual partners.
  Affected persons: service recipients and clients; prospective customers; business and contractual partners. Education and course participants.
• Purposes of processing: provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and commercial procedures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal Basis: Fulfillment of contract 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, processes and services:

• Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as "trainees") in order to be able to provide them with our training services. The data processed in this context, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the evaluation of performance and the evaluation of our services and those of the teachers. Within the scope of our activities, we may also process special categories of data, in particular information on the health of the trainees and data from which ethnic origin, political opinions, religious or ideological beliefs are evident. For this purpose, we obtain, if necessary, the express consent of the trainees and otherwise process the special categories of data only if it is necessary for the provision of the training services, for purposes of health care, social protection or the protection of vital interests of the trainees; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
• Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to be able to guarantee the security of our offer and to further develop it. The required information is marked as such within the scope of the order, order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Provision of the Online Offering and Web Hosting

We process the data of the users in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the contents and functions of our online services to the browser or the terminal device of the users.

• Processed data types: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved); Log data (e.g. log files concerning logins or the retrieval of data or access times.). Content data (e.g. textual or pictorial messages and contributions as well as the information concerning them, such as information on authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services).
• Zwecke der Verarbeitung: Bereitstellung unseres Onlineangebotes und Nutzerfreundlichkeit; Informationstechnische Infrastruktur (Betrieb und Bereitstellung von Informationssystemen und technischen Geräten (Computer, Server etc.)). Security measures.
• Storage 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 procedures, processes and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, message about 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. The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes are excluded from deletion until the final clarification of the respective incident.
• E-mail dispatch and hosting: The web hosting services used by us also include the dispatch, the receipt and the storage of e-mails. For these purposes, the addresses of the recipients as well as senders and also further information concerning the e-mail dispatch (e.g. the involved providers) as well as the contents of the respective e-mails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. We ask you to note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the recipient on our server; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that helps to deliver content of an online offer, especially large media files, such as graphics or program scripts, faster and more securely with the help of regionally distributed and Internet-connected servers; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offers; Service provider: Aut O’Mattic A8C Irland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).

Use of Cookies

The term "cookies" refers to functions that store information on and read information from users' end devices. Cookies can also be used in relation to various concerns, such as the functionality, security and convenience of online offers and the creation of analyses of visitor flows. We use cookies in accordance with the statutory provisions. For this purpose, we obtain the user's consent in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. These include, for example, the storage of settings and the ensuring of the functionality and security of our online offer. The consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

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

• Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his end device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be stored and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for range measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. within the scope of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their given consents at any time and also declare an objection to the processing in accordance with the statutory provisions, also by means of the privacy settings of their browser.

• Processed data types: Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6(1)(1)(a) GDPR).

Further information on processing procedures, processes and services:

• Processing of cookie data on the basis of consent: We use a consent management solution in which the user's consent to the use of cookies or to the procedures and providers named in the consent management solution is obtained. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on the users' end devices. Within the scope of this procedure, the users' consents are obtained for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure. The users also have the possibility to manage and revoke their consents. The declarations of consent are stored in order to avoid a renewed query and to be able to provide proof of the consent in accordance with the legal requirements. The storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or his device. Unless there is specific information on the providers of consent management services, the following general information applies: The duration of the storage of the consent is up to two years. In this process, a pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of consent (e.g. categories of cookies and/or service providers concerned) and information about the browser, the system and the end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• BorlabsCookie: Consent management: Procedure for obtaining, logging, managing and revoking consents, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and their processing; Service provider: Execution on servers and/or computers under own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language and types of consents and the time of their submission are stored server-side and in the cookie on the user's device.

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). The data of the readers are processed for the purposes of the publication medium only to the extent that it is necessary for its presentation and the communication between authors and readers or for reasons of security. Otherwise, we refer to the information on the processing of visitors to our publication medium within the scope of these data protection notices.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: 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 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 procedures, processes and services:

• Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
  
  Furthermore, we reserve the right, on the basis of our legitimate interests, to process the users' data for the purpose of spam detection.
  
  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 votes.
  
  The personal information provided in the context of comments and posts, any contact and website information, as well as the content, will be stored by us permanently until users object; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Retrieval of WordPress emojis and smileys: Retrieval of WordPress emojis and smileys - Within our WordPress blog, graphic emojis (or smileys), i.e. small graphic files that express feelings, are used for the purpose of efficiently integrating content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users' browsers; Service provider: Aut O’Mattic A8C Irland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (provided by the service provider).
• UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd., 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://updraftplus.com/. Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.

Contact and Inquiry Management

When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) as well as within the framework of existing user and business relationships, the information of the requesting persons is processed, insofar as this is necessary to answer the contact requests and any requested measures.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information concerning them, such as information on authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing: communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Storage 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). Performance of contract and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR).

Further information on processing procedures, processes and services:

• Contact form: When you contact us via our contact form, by e-mail or other means of communication, we process the personal data transmitted to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; Legal bases: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your possibilities of objection.

You can also contact us in alternative ways, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.

However, we would also like to point out to our communication partners that, although the providers of the messenger services cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

Information on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, on their own initiative, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of the needs of our communication partners in communication via messenger. Furthermore, we would like to point out that we do not initially transmit the contact data provided to us to the messenger services without your consent.

• Processed data types: Contact data (e.g. postal and e-mail addresses or
• Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as "newsletters") exclusively with the consent of the recipients or on the basis of a legal basis. If the contents of a newsletter are mentioned within the scope of a registration for the newsletter, these contents are decisive for the consent of the users. To register for our newsletter, it is usually sufficient to provide your e-mail address. However, in order to be able to offer you a personalised service, we may ask you to provide your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

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

The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Information about us, our services, promotions and offers.

• Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Communication partners.
• Purposes of processing: Direct marketing (e.g. by e-mail or post).
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Possibility of objection (opt-out): You can cancel the receipt of 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 otherwise use one of the contact options given above, preferably e-mail, for this purpose.

Further information on processing procedures, processes and services:

• Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or that of the server when the newsletter is opened, if we use a shipping service provider. 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, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations serve to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the profiles of the users">Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Customer Reviews and Evaluation Procedures

We participate in review and evaluation procedures to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating evaluation platforms or procedures, the general terms and conditions or terms of use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the evaluating persons have actually made use of our services, we transmit the data required for this purpose with regard to the customer and the service used to the respective evaluation platform (including name, e-mail address and order number or article number) with the consent of the customers. This data is used solely to verify the authenticity of the user.

• Processed data types: Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online services).
• Purposes of processing: feedback (e.g. collecting feedback via online form). Marketing.
• Legal bases: Legitimate interests (Art. 6 para. 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 area 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, the data of users within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are likely to correspond to the interests of the users. Therefore, cookies are usually stored on the computers of the users, in which the user behaviour and the interests of the users are stored. In addition, data independent of the devices used by the users can also be stored in the user profiles (in particular if they are members of the respective platforms and are logged in there).

For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information of the operators of the respective networks.

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

• Processed data types: Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as the information concerning them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: communication; feedback (e.g. collecting feedback via online form). Public relations.
• Storage 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 procedures, processes and services:

• LinkedIn: Social Network - Together with LinkedIn Ireland Unlimited Company, we are jointly responsible for the collection (but not the further processing) of visitor data used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, seniority level, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
  We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, address requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is exclusively the responsibility of LinkedIn Ireland Unlimited Company, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Right to Object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plug-ins and Embedded Features and Content

We integrate functional and content elements into our online offering, which are sourced 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 users' IP addresses, as they would not be able to send the content to their browsers without an 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 for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. "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 users' devices and may include technical information about the browser and operating system, referring websites, visit duration, and other details about the use of our online offering, but can also be combined with such information from other sources.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention 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, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of Processing: Provision of our online offering and user-friendliness.
• Storage 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 stated, 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 procedures, processes and services:

• Google Fonts (Sourced from Google Server): Sourcing of fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible licensing restrictions. The user's IP address is communicated to the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted, which is necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with Google Fonts' Cascading Style Sheets (CSS) and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, as well as the referrer URL (i.e., the website where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a specific font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the "Analytics" page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations based on the number of font requests can be generated. According to Google, it does not use any of the information collected by Google Fonts to create end-user profiles or to display targeted advertisements; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for Third-Country Transfers: Data Privacy Framework (DPF). Further Information: https://developers.google.com/fonts/faq/privacy?hl=de.