Privacy Policy

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").

The terms used are not gender-specific.

Last Update: 8. May 2026

Created with Datenschutz-Generator.de by Dr. jur. Thomas Schwenke

Table of contents

1. Preamble
2. Controller
3. Overview of processing operations
4. Relevant legal bases
5. Security Precautions
6. International data transfers
7. General Information on Data Retention and Deletion
8. Rights of Data Subjects
9. Business processes and operations
10. Provision of online services and web hosting
11. Use of Cookies
12. Contact and Inquiry Management
13. Artificial Intelligence (AI)
14. Cloud Services
15. Online Marketing
16. Profiles in Social Networks (Social Media)
17. Plugins and embedded functions and content
18. Changes and Updates
19. Terminology and Definitions

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services"). The terms used are not gender-specific.

Controller

Daniel Gmainer-Pranzl
Im Stadtgut Zone A1
4407 Steyr-Gleink

E-mail address: office@gmainer-pranzl.at
Legal Notice: https://www.gmainer-pranzl.at/impressum

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data	Categories of Data Subjects	Purposes of Processing
Inventory data Payment Data Contact data Content data Contract data Usage data Meta, communication and process data Images and/or video recordings Log data	Service recipients and clients Employees Prospective customers Communication partner Users Business and contractual partners Third parties	Provision of contractual services Communication Security measures Web Analytics Targeting Office and organisational procedures Affiliate Tracking Feedback Marketing Profiles with user-related information Provision of online services IT infrastructure Financial and Payment Management Public relations Sales promotion Business processes Artificial Intelligence (AI)

Relevant legal bases

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

• Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – 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.
• Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate Interests (Article 6 (1) (f) GDPR) – the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Austria. This includes in particular the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). In particular, the Data Protection Act contains special provisions on the right of access, rectification or cancellation, processing of special categories of personal data, processing for other purposes and transmission and automated decision making in individual cases.

Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data based on the Federal Act on Data Protection (referred to as "Swiss DPA"). Unlike the GDPR, for instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).

Reference to the applicability of the GDPR and the Swiss DPA: This privacy policy is intended to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). Where references are made to concepts such as the processing of personal data, legitimate interests, or special categories of data, these references are to be understood in accordance with the applicable data protection laws. Within the scope of application of the Swiss FADP, the legal interpretation of these terms is determined exclusively by Swiss law.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

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

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 the disclosure or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal address of the respective provider or when explicitly mentioned in the privacy policy regarding 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 has been recognized as a secure legal framework by the EU Commission's adequacy decision of July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the EU Commission's requirements and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Contractual Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and if Standard Contractual Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, particularly Standard Contractual Clauses, explicit 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.

We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or special interests require a 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 protection of 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 specifically applicable to certain processing processes. In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails. Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Data Retention under Austrian law

The following general retention periods apply under Austrian law to the retention and archiving of personal data, insofar as such retention is necessary to comply with statutory obligations or to safeguard legitimate interests:

• 7 years – Personal data processed in connection with tax-relevant business records are retained for a period of seven years pursuant to the Austrian Federal Fiscal Code (Section 132 BAO) and the Austrian Commercial Code (Sections 190–212 UGB). This includes, in particular, books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting records, invoices, received and sent commercial or business correspondence, as well as all other documents relevant for tax assessment purposes. The retention period begins at the end of the calendar year in which the last entry was made.
• 3 years – Data that are required for the assertion, exercise or defence of warranty claims, claims for damages or other contractual claims are retained for the duration of the applicable statutory limitation period, which is generally three years pursuant to Section 1489 of the Austrian Civil Code (ABGB), provided that no longer statutory retention obligations apply.

Data Retention under German law

The following general deadlines apply for the retention and archiving according to German law:

• 10 Years – Fiscal Code/Commercial Code – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 AO, Section 257 Paragraph 1 No. 1 HGB).
• 8 years – Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a AO, Section 257 Paragraph 1 No. 4 HGB).
• 6 Years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents significant for taxation purposes (Section 147 Paragraph 1 No. 2, 3, 5 AO, Section 257 Paragraph 1 No. 2 and 3 HGB).
• 3 Years – Data required to consider potential warranty and compensation claims or similar contractual claims, based on previous business experiences and common industry practices. This period begins at the end of the year in which the relevant contractual transaction took place (Sections 195, 199 German Civil Code).

Data Retention under Swiss law

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
• 10 years – Data necessary to consider potential claims for damages or similar contractual claims and rights (Articles 127, 130 OR), unless a shorter period of five years applies (Article 128 OR).

Start of the period at the end of the year: If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred.

Rights of Data Subjects

Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:

• Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time.
• Right of withdrawal for consents: You have the right to revoke consents at any time.
• Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
• Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
• Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
• Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
• Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DPA: As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

• Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.
• Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.
• Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
• Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

Business processes and operations

Personal data of service recipients and clients – including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted.

Processed data types:

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

Data subjects:

Service recipients and clients; Prospective customers; Communication partner; Business and contractual partners; Third parties; Users; Employees.

Purposes of processing and legitimate interests:

Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management; Information technology infrastructure.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

• Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
• General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
• Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
• Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
• Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
• Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Provision of online services and web hosting

We process user data 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 content and functions of our online services to the user's browser or terminal device.

Processed data types:

Usage data; Meta, communication and process data; Log data.

Data subjects:

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

Purposes of processing and legitimate interests:

Provision of our online services and usability; Information technology infrastructure; Security measures.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
• Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
• ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, Inhaber: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://all-inkl.com/; Privacy Policy: https://all-inkl.com/datenschutzinformationen/. Data Processing Agreement: Provided by the service provider.

Use of Cookies

The term "cookies" refers to functions that store information on users' devices and read it from them. Cookies can also be used for different purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users' consent in advance. If consent is not required, we rely on our legitimate interests. Consent can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.

Information on legal data protection bases: Whether we process personal data using cookies depends on users' consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as outlined in this section and in the context of the respective services and procedures.

Storage duration: The following types of cookies are distinguished based on their storage duration:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user revisits a website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that these are permanent and may have a storage duration of up to two years.

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

Processed data types:

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

Data subjects:

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

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR).

Further information on processing methods, procedures and services used:

• Processing Cookie Data on the Basis of Consent: We implement a consent management solution that obtains users' consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users' devices. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device. The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent, as well as information about the browser, system, and device used; Legal Basis: Consent (Article 6 (1) (a) GDPR).

Contact and Inquiry Management

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

Processed data types:

Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

Data subjects:

Communication partner (Recipients of e-mails, letters, etc.).

Purposes of processing and legitimate interests:

Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

• Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

Processed data types:

Content data; Usage data.

Data subjects:

Users (e.g. website visitors, users of online services); Third parties.

Purposes of processing and legitimate interests:

Artificial Intelligence (AI).

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Adobe AI: AI-powered tools and features in Adobe products that support creative processes. Adobe AI offers functions such as automatic image editing, content generation, and intelligent image adjustments to optimize the creative workflow; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://business.adobe.com/uk/ai/adobe-genai.html; Privacy Policy: https://www.adobe.com/privacy.html; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).
• ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions; Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://openai.com/chatgpt/overview/; Privacy Policy: https://openai.com/policies/privacy-policy/; Opt-Out: https://privacy.openai.com/policies?modal=select-subject.
• OpenAI API: An API (application programming interface) for artificial intelligence that provides developers with access to language and image models. It supports the integration of functions such as text generation, natural language processing (NLP), conversation, code creation, translation, as well as image generation and analysis into their own applications; Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://openai.com/; Privacy Policy: https://openai.com/policies/privacy-policy/; Data Processing Agreement: https://openai.com/policies/data-processing-addendum; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses; Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses. Opt-Out: https://privacy.openai.com/policies?modal=select-subject.
• Manus AI: Manus is an autonomous AI agent platform that not only answers tasks but also plans and executes them independently. The platform uses large language models and a REST API to automate workflows, perform data analysis, conduct web research, generate code, as well as create and process various types of files; Service provider: Butterfly Effect Pte. Ltd., 109 North Bridge Road #06-W112, 179097 Singapore; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://manus.im/; Privacy Policy: https://manus.im/privacy; Data Processing Agreement: https://manus.im/policies/data-processing-addendum. Basis for third-country transfers: EEA – Standard Contractual Clauses; Switzerland – Standard Contractual Clauses.
• Claude API: Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.anthropic.com/; Privacy Policy: https://www.anthropic.com/legal/privacy; Data Processing Agreement: https://www.anthropic.com/legal/data-processing-addendum. Basis for third-country transfers: EEA – Standard Contractual Clauses; Switzerland – Standard Contractual Clauses.

Cloud Services

We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a Service") provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users' devices for web analysis or to remember user settings.

Processed data types:

Inventory data; Contact data; Content data; Usage data; Images and/or video recordings; Meta, communication and process data.

Data subjects:

Prospective customers; Communication partner; Business and contractual partners; Users; Third parties.

Purposes of processing and legitimate interests:

Office and organisational procedures; Information technology infrastructure; Provision of contractual services and fulfillment of contractual obligations; Communication; Organisational and Administrative Procedures; Business processes and management procedures.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Adobe Creative Cloud: Cloud storage, cloud infrastructure services, and cloud-based application software, among others for photo editing, video editing, graphic design, web development; Service provider: Adobe Systems Software Ireland, 4-6, Riverwalk Drive, Citywest Business Campus, Brownsbarn, Dublin 24, D24 DCW0, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.adobe.com/creativecloud.html; Privacy Policy: https://www.adobe.com/privacy.html; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).
• Apple iCloud: Cloud storage service; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.apple.com; Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.
• WeTransfer: Transferring files over the Internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://wetransfer.com; Privacy Policy: https://wetransfer.com/legal/privacy.
• Microsoft 365 Outlook: The use of email and calendar functions for communication and organisation of meetings involves processing contact data (name, email address), content data (messages, attachments, meeting content) and metadata. The retention of emails and calendar entries is determined by policies set by the administrator or user; by default, there is no automatic deletion. Mailboxes and calendars are generally removed 30 days after departure. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://microsoft.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data Processing Agreement: Microsoft DPA. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Standard Contractual Clauses; Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses.

Online Marketing

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Notes on revocation and objection: We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called "opt-out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. We therefore recommend the following additional opt-out options:

• Europe: https://www.youronlinechoices.eu
• Canada: https://www.youradchoices.ca/choices
• USA / Cross-regional: https://optout.aboutads.info

Processed data types:

Usage data; Meta, communication and process data.

Data subjects:

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

Purposes of processing and legitimate interests:

Web Analytics; Targeting; Affiliate Tracking; Marketing; Profiles with user-related information; Provision of our online services and usability.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years.

Security measures:

IP Masking (Pseudonymization of the IP address).

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Google Ad Manager: We use the service "Google Ad Manager" to place ads in the Google advertising network (e.g. in search results, videos, websites, etc.). The Google Ad Manager stands out because ads are displayed in real time based on users' presumed interests. This allows us to display ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest, and measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF); Further Information: https://business.safety.google/adsservices/.
• Google Analytics 4 (GA4): We use Google Analytics 4 to measure and analyse visitor behaviour on our online service. This is done on the basis of your consent. Google Analytics 4 uses cookies and similar technologies. The information collected about your use of our online service is usually transferred to a Google server in the USA and stored there. We use IP anonymisation (IP masking): your IP address is truncated within the EU/EEA before transmission. The transmitted IP address is not combined with other Google data; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF); Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Profiles in Social Networks (Social Media)

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

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored.

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

Processed data types:

Contact data; Content data; Usage data.

Data subjects:

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

Purposes of processing and legitimate interests:

Communication; Feedback; Public relations.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

Legal Basis:

Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Instagram: Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
• Vimeo: Platform for the provision and delivery of video content; Service provider: Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://vimeo.com; Privacy Policy: https://vimeo.com/legal/privacy; Data Processing Agreement: https://vimeo.com/legal/enterprise-terms/dpa. Basis for third-country transfers: EEA – Standard Contractual Clauses; Switzerland – Standard Contractual Clauses.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as "Content").

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes.

Processed data types:

Usage data; Meta, communication and process data.

Data subjects:

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

Purposes of processing and legitimate interests:

Provision of our online services and usability.

Retention and deletion:

Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years.

Legal Basis:

Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

• Google Fonts (from Google Server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user's IP address 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) are transmitted which are necessary for the provision of the fonts depending on the devices used and the technical environment. IP addresses are not logged or stored on Google servers and they are not analyzed. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Further Information: https://developers.google.com/fonts/faq/privacy?hl=en.

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

Affiliate Tracking:

Custom Audiences refers to the process of determining target groups for advertising purposes, e.g. the display of advertisements. For example, a user's interest in certain products or topics on the Internet may be used to conclude that the user is interested in advertisements for similar products or the online store in which the user viewed the products. "Lookalike Audiences" is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are typically used.

Artificial Intelligence (AI):

The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.

Contact data:

Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.

Content data:

Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.

Contract data:

Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement.

Controller:

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Employees:

As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.

Inventory data:

Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs).

Log data:

Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system.

Meta, communication and process data:

Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths.

Payment Data:

Payment data comprise all information necessary for processing payment transactions between buyers and sellers. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information.

Personal Data:

"Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing:

The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.

Profiles with user-related information:

The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.).

Targeting:

"Tracking" is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.

Usage data:

Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data.

Web Analytics:

Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.