Privacy policy for all services

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording

Who is the responsible party for the recording of data (i.e., the “controller”)?

The data is processed by the operator, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by external service providers (hosts). Personal data collected on this website are stored on the servers of the hosts. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The hosts are used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our hosts will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

Site operators in the sense of § 5 TMG

Hetzner Online GmbH
Industriestr. 25
91710 Gunzenhausen

Webleon GmbH
Zeppelinstr. 11
85748 Garching

E-Mail: [email protected]
Phone: 08945819999
USt-IdNr.: DE306333247

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host.

3. General information and mandatory information

Data protection

The operators take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

A variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller is:

Solutions2Share GmbH
Dieter-Streng-Str. 3
90766 Fürth
Germany

Phone: +4991113133660

Our company has appointed a data protection officer. If you have any questions regarding data protection, you can reach the data protection officer at [email protected].

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

Information on data transfer to the USA

We use, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate, and permanently store your data on US servers for monitoring purposes.  We have no influence over these processing activities.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the operator uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

4. Recording of data

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

Server log files

The provider and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator has a legitimate interest in the technically error free depiction and the optimization of the pages. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Calendly

We use the “Calendly” tool for booking appointments. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA (hereinafter “Calendly”).

To book an appointment, enter the requested data and the desired date in the screen provided. The data entered will be used for planning, executing and, if necessary, for the follow-up of the appointment.

The data you have entered will remain with us until you ask us to delete it, revoke your consent for storage or the purpose for which the data was stored ceases to apply. Mandatory legal provisions – in particular retention periods – remain unaffected.

The legal basis for data processing is Art. 6(1)(f) of the GDPR). The operator has a justified interest in making appointments with interested parties and customers in as uncomplicated a manner as possible.

The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://calendly.com/pages/dpa.

Contract data processing agreement

We have concluded a contract for order processing with Calendly. This is a data protection contract that guarantees that Calendly only processes the personal data of our visitors according to our instructions and in compliance with the GDPR.

Zoho CRM

We use Zoho CRM. Provider is Zoho Corporation GmbH., Estancia IT Park, Plot No. 140 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, India (hereinafter “Zoho CRM”).

Zoho CRM enables us, in particular, to manage existing and potential customers and customer contacts and to organize sales and communication processes. Using the CRM system also enables us to analyze and optimize our customer-related processes. The customer data is stored on Zoho CRM’s servers. Details of Zoho CRM’s functions can be found here: https://www.zoho.com/de/crm/help/getting-started/key-functions.html.

The use of Zoho CRM is based on Art. 6 para. 1 lit. f GDPR. The operator has a legitimate interest the most efficient customer management and customer communication. If consent has been requested, processing will be performed exclusively on the basis of Art. 6 para. 1 letter a GDPR; consent may be revoked at any time.

The data transfer to third countries outside the European Union is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

Details can be found in the Zoho CRM privacy policy: https://www.zoho.com/privacy.html and https://www.zoho.com/gdpr.html.

Execution of a contract data processing agreement

We have concluded an order processing contract with Zoho CRM. This is a contract that is required by data protection law and ensures that Zoho CRM processes the personal data of our visitors only according to our instructions and in compliance with the GDPR.

ClickUp

We use ClickUp. This company is not located in the EU. Thus, it is a provider from a third country. An appropriate check on confidentiality etc. has of course been carried out. ATTN: Privacy Agent ClickUp, 363 Fifth Ave. Suite 300, San Diego, CA 92101 (hereinafter “ClickUp”).

ClickUp helps us structure our tasks and to-dos. Because this application has so many capabilities, we can also include documents or data from you here. Details about ClickUp’s features can be found here: https://clickup.com/features.

Data transfer to third countries outside the European Union is based on the standard contractual clauses of the EU Commission. Details can be found here: https://clickup.com/dpa.

Details can be found in ClickUp’s privacy policy: https://clickup.com/privacy.

Data protection provisions regarding the use of Microsoft Azure

Personal data that you have provided by licensing the software solutions of the controller will be processed and maintained with Microsoft Azure.

The address of the system used is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”).

The Microsoft servers are located in the USA. As soon as personal data is collected by licensing one of our software solutions, personal data is transferred to a third country. In accordance with the EU-US Privacy Shield, the EU Commission has determined the adequacy of the data protection level for the USA on the basis of this Privacy Shield, according to which data transmission in accordance with Art 45 DS-GMO is permissible, taking into account further data protection requirements.

The data that are transmitted to Microsoft are only used for the purpose of identification and access to our products and will only be used for this purpose, not for advertising purposes, unless this has been agreed to separately and explicitly. For details about Microsoft’s use of your information and your rights and choices to protect your personal information, please refer to Microsoft’s privacy policy: https://privacy.microsoft.com/en-us/privacystatement

The comment function

When you use the comment function, information on the time the comment was generated and your e-mail-address and, if you are not posting anonymously, the username you have selected will be archived in addition to your comments.

Storage of the IP address

Our comment function stores the IP addresses of all users who enter comments. Given that we do not review the comments prior to publishing them, we need this information in order to take action against the author in the event of rights violations, such as defamation or propaganda.

Storage period for comments

Comments and any affiliated information shall be stored by us and remain until the content the comment pertained to has been deleted in its entirety or if the comments had to be deleted for legal reasons (e.g., insulting comments).

Legal basis

Comments are stored on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You have the right to revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

5. Analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools. If the relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; the consent can be revoked at any time.

Google Analytics

We use functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the operator to analyze the behavior patterns of visitors. To that end, the operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). We use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

We have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics

We use the “demographic characteristics” function of Google Analytics, to be able to display to the visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender, and interests of the visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third-party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.

Google Analytics E-Commerce-Tracking

We use the “E-Commerce Tracking” function of Google Analytics. With the assistance of E-Commerce Tracking, the operator is in a position to analyze the purchasing patterns of visitors with the aim of improving the operator’s online marketing campaigns. In this context, information, such as the orders placed, the average order values, shipping costs and the time from viewing the product to making the purchasing decision are tracked. These data may be consolidated by Google under a transaction ID, which is allocated to the respective user or the user’s device.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

Google Ads

The operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of Google Ads is based on  Art. 6 Sect. 1 lit. et seq. GDPR. The operator has a legitimate interest in marketing the operator’s services and products as effectively as possible.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

Google Remarketing

We use the functions of Google Analytics Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Remarketing analyzes your user patterns (e.g., clicks on specific products), to allocate a certain advertising target groups to you and to subsequently display matching online offers to you when you visit other online offers (remarketing or retargeting).

Moreover, it is possible to link the advertising target groups generated with Google Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).

If you have a Google account, you have the option to object to personalized advertising under the following link: https://www.google.com/settings/ads/onweb/.

The use of Google Remarketing is based on Art. 6 1 lit. et seq. GDPR. The operator has a legitimate interest in the marketing of the operator’s products that is as effective as possible. If a respective declaration of consent was requested, processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be revoked at any time.

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.

Formation of Target Groups with Customer Reconciliation

For the formation of target groups, we use, among other things, the Google Remarketing customer reconciliation feature. To achieve this, we transfer certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are Google users and are logged into their Google accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search engine) are displayed for them to view.

Google Conversion-Tracking

We use Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of Art. 6 Sect. 1 lit. et seq. GDPR. The operator has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g., concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en

Facebook Pixel

We use the visitor action pixel from Facebook for conversion measurement. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the USA and other third countries.

In this way, the behavior of page visitors can be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.

The collected data is anonymous for us as the operator, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Use Policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.

The use of Facebook Pixel is based on Art. 6 (1) lit. f DSGVO. The operator has a legitimate interest in effective advertising measures including social media. If a corresponding consent has been requested (e.g., consent to store cookies), the processing is carried out exclusively on the basis of Art. 6 (1) a DSGVO; the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://www.facebook.com/help/566994660333381.

You can find further information on protecting your privacy in Facebook’s privacy notices: https://www.facebook.com/about/privacy/.

You can also deactivate the “Custom Audiences” remarketing function in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged into Facebook.

If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: https://www.youronlinechoices.com/uk/your-ad-choices.

Microsoft Clarity

We use the Microsoft Clarity service for statistical analysis. The provider of Microsoft Clarity is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052 USA (“Microsoft”).

Within the scope of this service, a transmission of data to the USA takes place or cannot be excluded.

Microsoft Clarity uses cookies that enable an analysis of the use, as well as a so-called tracking code that is executed when this service is called up. The information collected, such as your IP address, location, time or frequency of visits, is transmitted to Microsoft and stored there. According to information from Microsoft, this can also be used for advertising purposes and other services related to the use of our website and the use of the Internet. We use Microsoft Clarity with the so-called anonymization function. Through this function, Microsoft already shortens the IP address within the EU or EEA.

The processing of your data is based on your consent pursuant to Art 6 (1) a DSGVO. You can revoke this consent at any time for the future.

You can find Microsoft’s data protection information in the Microsoft Privacy Statement at https://privacy.microsoft.com/en-us/privacystatement.

For further information and the Microsoft Clarity privacy statement, please visit https://clarity.microsoft.com/terms.

Zoho PageSense

Anonymized usage data is collected using PageSense (https://zoho.eu/pagesense), an analytics service provided by Zoho Corporation.

Page Sense records visits and clicks completely anonymously. There is no traceability to individual visitor data. PageSense enables us, in the form of a heat map, to monitor the general use and, as a result, to display important content at the right place on the individual pages. During the recording of the heat map, the login name becomes visible. However, no usage data or personal data is collected or stored, i.e. the analysis is anonymous.

For more information on data processing by Zoho, please visit https://www.zoho.com/privacy.html.

The legal basis for data processing is Article 6 (1) (f) of the General Data Protection Regulation DSGVO. The data processing serves to protect our legitimate interests, namely for market research and demand-oriented design and optimization. You can object to the data processing within the scope of PageSense.

6. Newsletter

Newsletter data

If you would like to subscribe to the newsletter, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

Zoho Campaigns

We use Zoho Campaigns to send out newsletters. Provider is Zoho Corporation GmbH., Estancia IT Park, Plot no. 140 151, GST Road, Vallancherry Village, Chengalpattu Taluk, Kanchipuram District 603 202, India (hereinafter “Zoho Campaigns”).

Zoho Campaigns is a service that can be used, in particular, to organize and analyze the sending of newsletters. The information you enter to subscribe to the newsletter is stored on Zoho Campaigns’s servers.

Data analysis by Zoho Campaigns

Zoho Campaigns allows us to analyze our newsletter campaigns. For example, we can see whether a newsletter message has been opened and which links have been clicked on, if any. In this way we can determine which links have been clicked on most often.

We can also see if certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can see whether you have made a purchase after clicking on the newsletter. If you do not want to receive analyses of Zoho Campaigns, you must unsubscribe from the newsletter. We provide a link to this in every newsletter message. Zoho Campaigns also allows us to classify the recipients of the newsletter into different categories (“clustering”). The newsletter recipients can be classified, for example, by age, gender or place of residence. In this way, the newsletter can be better adapted to the respective target groups. If you do not wish to receive analyses of Zoho Campaigns, you must unsubscribe from the newsletter. You will find a link to this in every newsletter message.

Detailed information about the characteristics of Zoho Campaigns can be found at the following link: https://www.zoho.com/campaigns/features.html.

The Zoho Campaigns’s privacy policy can be found at https://www.zoho.com/privacy.html and https://www.zoho.com/gdpr.html.

Legal basis

The data processing is based on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time with effect for the future.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

Duration of storage

The data that you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list or deleted after the newsletter has been cancelled. We reserve the right to delete email addresses within the scope of our legitimate interest under Art. 6 para. 1 lit. f GDPR. Data stored by us for other purposes remain unaffected.

After you have been removed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in compliance with legal requirements when sending out newsletters (legitimate interest in the sense of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

Contract data processing agreement

We have concluded an order processing contract with Zoho Campaigns. This is a contract that is required by data protection law and ensures that Zoho Campaigns processes the personal data of our visitors only according to our instructions and in compliance with the GDPR.

7. Plug-ins and Tools

YouTube with expanded data protection integration

We embed videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Akismet Spam Protection

Our offer uses the service “Akismet”, which is offered by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.

Automattic is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).

More information on the collection and use of data by Akismet can be found in Automattic’s privacy policy: https://automattic.com/privacy/.

Zapier

We use “Zapier” to connect different web apps. This allows us to automate actions between different web apps.

Zapier is a service of Zapier Inc, 548 Market St #6241, San Francisco, CA 94104, USA.

When using Zapier, it is not excluded that data is transferred to servers of Zapier in the USA. We have concluded an order processing agreement with Zapier. In addition, the data processing is secured by the EU standard contractual clauses. We use Zapier to automate actions between different apps in order to improve our internet presence and make it more time-efficient, which is also our legitimate interest according to Art. 6 (1) lit. f) DSGVO.

For more information on data protection at Zapier, please visit: https://zapier.com/privacy/

Uteach

We use Uteach to deliver our online courses. The provider is Uteach, 651 N Broad St Suite 206, Middletown, Delaware, USA (hereinafter Uteach).

When using Uteach, it is not excluded that data is transferred to servers of Uteach in the USA. Uteach uses AWS servers which give an opportunity to keep the data safe and use different servers located in different areas which allow us to use data more quickly.

The use of Uteach is based on Art. 6(1)(f) GDPR. The operator has a legitimate interest in providing its online course content in an appealing and functional manner.

Data transmission to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://uteach.io/gdpr.

For more information on data protection at Uteach, please visit: https://uteach.io/pages/privacy-policy.

8. eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process and use personal data concerning the use (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them.

The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.

Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with companies entrusted with the shipment of goods or the financial institution tasked with the processing of payments. Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

9. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 sentence 1 lit. b GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6 para. 1 lit. f GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.

Execution of a contract data processing agreement

We have entered into a contract data processing agreement with the provider of Microsoft Teams.