Privacy Policy

The processing of your personal data is limited to data that is necessary for the operation of a functional website and for the provision of our content, products and services. The processing of our users' personal data is based on the agreed purposes or a legal basis. We only collect personal data that is required to carry out and process our tasks and services or that you provide to us voluntarily. Depending on the occasion and purpose of the processing, we process different data about you.

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3.1 Technical data

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When you use our website, app or other electronic offerings ("website"), we collect the IP address of your end device and other technical data to ensure the functionality and security of these offerings. This data also includes logs in which the use of our systems is recorded. We generally store technical data for 6 months. In order to ensure the functionality of these offers, we can also assign you or your end device an individual code (e.g. in the form of a cookie, see section 14). The technical data itself does not allow any conclusions to be drawn about your identity. However, in the context of user accounts, registrations, access controls or the processing of contracts, they can be linked to other data categories (and thus possibly to your person).

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The technical data includes, among other things

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• the IP address and information about the operating system of your end device

• Name and URL of the requested website

• the date, region and time of use, GMT time zone difference

• notification of whether the request was successful (access status/http status code)

• amount of data transferred

• Websites that are accessed via our website

• Website from which the access is made (so-called referrer URL)

• the type of browser you use to access our online offering

• the name of your internet provider

• type and version of the browser used and other information provided by the user (such as geographical origin, language setting, add-ons used, screen resolution, etc.)

• Logs that are created in our systems (e.g. the log of user logins on our website).

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This can help us to design the website accordingly or, for example, to display a subpage for your region. We know which provider you use to access our website (and therefore also the region) based on the IP address, but this does not usually tell us who you are. However, this changes, for example, if you create a user account, as personal data can then be linked to technical data (e.g. we can know which browser you use to access an account via our website).

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3.2 Registration data/newsletter order

Certain products and services can only be used with a user account or registration, which can be done directly with us or via our external login service providers. In doing so, you must provide us with certain data and we collect data on the use of the offer or service. We generally retain registration data for 12 months after the end of the use of the service or the termination of the user account.

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The registration data includes, among other things

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• Information you provide when you create an account on our website (e.g. username, password, name, email, phone number, account details)

• Contact information if you subscribe to our newsletter.

• Ordering our products and services.

• When you register with us, we create a user account for you with the following data:

• Contact information

• Credit card information

• IP address

• User ID (see technical data)

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3.3 Communication data

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When you contact us via the contact form, by email, telephone, chat, letter or other means of communication, we record the data exchanged between you and us, including your contact details and the marginal data of the communication. If we record telephone conversations or video conferences, we will specifically inform you of this. If we want or need to establish your identity, e.g. if you request information, we will collect data to identify you (e.g. a copy of an identity document). As a rule, we store this data for 12 months from the last exchange with you. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. E-mails in personal mailboxes and written correspondence are generally stored for at least 10 years. Chats are generally stored for 2 years.

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The communication data includes

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• your name and contact details

• the manner, place and time of communication and, as a rule, its content (i.e. the content of e-mails, letters, chats, etc.). This data may also contain information about third parties. We may also use your ID number for identification purposes.

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3.4 Master data

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We define master data as the basic data that we require in addition to the contract data (see below) for the processing of our contractual and other business relationships or for marketing and advertising purposes, such as name, contact details and information, e.g. about your role and function, your bank account(s), your date of birth, customer history, powers of attorney, signature authorizations and declarations of consent. We process your master data if you are a customer or other business contact or work for one (e.g. as a contact person of the business partner), or because we want to contact you for our own purposes or the purposes of a contractual partner (e.g. as part of marketing and advertising, with newsletters, etc.). We receive master data from you yourself (e.g. when you make a purchase or register), from bodies for which you work, or from third parties such as our contractual partners, associations and address dealers, and from publicly accessible sources such as public registers or the internet (websites, social media, etc.). As a rule, we store this data for 10 years from the last exchange with you, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. In the case of pure marketing and advertising contacts, the period is normally much shorter, usually no more than 2 years since the last contact.

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Master data is not collected across the board for every contact. Rather, the collection of master data depends on the individual case and the purpose of the processing. In general, it may include

• Your name

• your address

• e-mail address

• Telephone number and other contact details

• your gender

• Date of birth

• Nationality

• Data on related persons

• Websites

• Social media profiles

• Photos and videos

• Copies of identity cards

• Details of your relationship with us (e.g. customer, supplier, visitor, service provider or service recipient, etc.)

• Details of your status, assignments, classifications and mailing lists

• Details of interactions with you

• reports

• Official documents (e.g. extracts from the commercial register, permits)

• Payment information (e.g. bank details, account number and credit card details)

• Declarations of consent and opt-out information

For customers, suppliers and partners, master data also includes information about the role or function in the company, qualifications and information about superiors, employees and information about interactions with these persons.

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3.5 Contract data

We collect contract data in connection with the conclusion or performance of a contract, e.g. information about the products and the services provided or to be provided, as well as data from the period prior to the conclusion of the contract, information that is required or used for the performance of a contract, and information about feedback (e.g. complaints, feedback on satisfaction, etc.). We generally collect this data from you, from contractual partners and from third parties involved in the execution of the contract, but also from third-party sources and from publicly accessible sources. We generally store this data for 10 years from the last contractual activity, but at least from the end of the contract. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons.

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The contract data includes, among other things

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• information about the conclusion of the contract, about your contracts, e.g. the type and date of conclusion and its duration

• the performance and administration of the contracts, e.g. information in connection with billing, customer service, technical support and the enforcement of contractual claims

• information about defects, complaints and contract amendments as well as information about customer satisfaction, which we can collect, for example, through surveys

• Financial data, such as creditworthiness information (i.e. information that allows conclusions to be drawn about the probability of payment of receivables), information about reminders and debt collection.

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We receive some of this data from you (e.g. when you make payments), but also from credit agencies and debt collection agencies as well as from public sources (e.g. commercial register).

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3.6 Behavioral and preference data

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Depending on the relationship we have with you, we try to get to know you and better tailor our products, services and offers to you. To do this, we collect and use data about your behavior and preferences. We do this by evaluating information about your behavior in our area, and we may also supplement this information with information from third parties, including from publicly available sources. Based on this, we can, for example, calculate the probability that you will use certain services or behave in a certain way. Some of the data processed for this purpose is already known to us (e.g. when you use our services), or we obtain this data by recording your behavior (e.g. how you navigate our website). We anonymize or delete this data when it is no longer relevant for the purposes pursued, which can be between 2-3 weeks and 24 months (for product and service preferences), depending on the type of data. This period may be longer if this is necessary for reasons of proof or to comply with legal or contractual requirements or for technical reasons. We describe how tracking works on our website in section 14.

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Behavioral and preference data includes information about certain actions, such as your response to electronic communications (e.g. whether and when you opened an email) or your whereabouts, as well as your interaction with our social media profiles and your participation in prize draws, competitions and similar events.

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Preference data provides us with information about your needs, which products or services might be of interest to you or when and how you are likely to respond to messages from us. We obtain this information from the analysis of existing data, such as behavioral data, so that we can get to know you better, tailor our advice and offers more precisely to you and generally improve our offers. In order to improve the quality of our analyses, we can link this data with other data that we also obtain from third parties or public sources (e.g. the Internet).

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Behavioral and preference data can be evaluated on a personal basis (e.g. to show you personalized advertising), but also on a non-personal basis (e.g. for market research or product development). Behavioral and preference data can also be combined with other data (e.g. movement data can be used for contact tracing as part of a health protection concept).

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3.7 Other data

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We also collect data from you in other situations. In connection with official or court proceedings, for example, data is collected (such as files, evidence, etc.) that may also relate to you. We may also collect data for health protection reasons (e.g. as part of protection concepts). We may receive or produce photos, videos and audio recordings in which you may be recognizable (e.g. at events, through security cameras, etc.). We may also collect data about who enters certain buildings or has access rights to them and when (including during access controls, based on registration data or visitor lists, etc.), who participates in events or campaigns and when, or who uses our infrastructure and systems and when. The retention period for this data depends on the purpose and is limited to what is necessary. This ranges from a few days for many of the security cameras and usually a few weeks for contact tracing data to visitor data, which is usually stored for 3 months, to reports on events with images, which can be stored for several years or longer.

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You provide us with much of the data mentioned in this Section 3 yourself (e.g. via forms, in the context of communication with us, in connection with contracts, when using the website, etc.). You are not obliged to do so, subject to individual cases, e.g. as part of binding protection concepts (legal obligations). If you wish to conclude contracts with us or make use of services, you must also provide us with data as part of your contractual obligation in accordance with the relevant contract, in particular master, contract and guest access or registration data. When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you must provide us with registration data. For behavioral and preference data, however, you always have the option of objecting or not giving your consent.

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We only provide you with certain services if you provide us with registration data because we or our contractual partners want to know who is using our services, because it is technically necessary or because we want to communicate with you. If you or a person you represent (e.g. your employer) wishes to conclude or fulfill a contract with us, we must collect corresponding master data, contract data and communication data from you, and we process technical data if you wish to use our website or other electronic offers for this purpose. If you do not provide us with the data required for the conclusion and execution of the contract, you must expect that we will refuse to conclude the contract, that you will commit a breach of contract or that we will not fulfill the contract. Similarly, we can only send you a response to an inquiry from you if we process the relevant communication data and - if you communicate with us online - possibly also technical data. It is also not possible to use our website without providing us with technical data.

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Unless this is not permitted, we also obtain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media or the Internet, including social media) or from authorities and other third parties (e.g. credit agencies, address dealers, associations, contractual partners, Internet analysis services, etc.).

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The categories of personal data that we receive about you from third parties include, in particular, information from public registers, information that we learn in connection with official and legal proceedings, information in connection with your professional functions and activities (e.g. so that we can conclude and process transactions with your employer with your help), information about you in correspondence and meetings with third parties, creditworthiness information (insofar as we conduct business with you personally), information about you that people from your environment (family, advisors, legal representatives, etc.) provide to us so that we can conclude or process contracts with you or involve you (e.g. references, your address for deliveries, information about compliance with legal requirements such as fraud prevention, information about your creditworthiness, etc.). This includes, for example, references, your address for deliveries, powers of attorney, information to comply with legal requirements such as anti-fraud, anti-money laundering, anti-terrorism and export restrictions, information from banks, insurance companies and sales and other contractual partners of ours regarding the use or provision of services by you (e.g. payments, purchases, etc.), information from the media and the Internet about you (insofar as this is appropriate in the specific case). Your address and, if applicable, interests and other socio-demographic data (in particular for marketing and research) and data in connection with the use of third-party websites and online offers where this use can be attributed to you.

11. Your rights