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Saypacks

Privacy Policy

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

The terms used are gender-neutral.

Effective date: May 15, 2026.

Controller

Yan Philipp Geiß / Saypacks

Westbeverner Straße 14

48291, Telgte, Germany

Authorized representatives: Yan Philipp Geiß

Email address: [email protected]

Telephone: +4915254317556

Imprint: https://termloo.app/imprint

Overview of Processing Activities

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Data Processed

• Inventory data.

• Employee data.

• Payment data.

• Contact details.

• Content data.

• Contract data.

• Usage data.

• Meta, communication and procedural data.

• Log data.

Categories of Data Subjects

• Service recipients and clients.

• Employees.

• Interested parties.

• Communication partner.

• Users.

• Business and contractual partners.

• Third parties.

• Whistleblowers.

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.

• Communication.

• Security measures.

• Direct marketing.

• Reach measurement.

• Office and organizational procedures.

• Organizational and administrative procedures.

• Feedback.

• Marketing.

• Profiles with user-related information.

• Registration procedures.

• Provision of our online offering and user-friendliness.

• Information technology infrastructure.

• Whistleblower protection.

• Public relations.

• Sales promotion.

• Business processes and business procedures.

Relevant Legal Bases

Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.

• Fulfillment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or to carry out pre-contractual measures that are carried out at the request of the data subject.

• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary to fulfill a legal obligation to which the controller is subject.

• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - the processing is necessary to safeguard 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 outweigh them.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the law to protect against misuse of personal data during data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

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

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, ensuring availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use 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 transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the advanced and more secure version of SSL, ensures that all data transfers meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by displaying HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

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 as part of the use of third-party services or the disclosure or transmission of data to other people, bodies or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual protection ensures comprehensive protection of your data: the DPF provides the primary layer of protection, while the standard contractual clauses serve as additional security. Should any changes occur within the framework of the DPF, the standard contractual clauses will intervene as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.

For the individual service providers, we will inform you whether they are certified according to the DPF and whether standard contractual clauses exist. For more information about the DPF and a list of certified companies, visit the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/.

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the EU Commission's information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consent is revoked or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be stored for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

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

If there is more than one piece of information about the retention period or deletion period for a date, the longest period always applies. We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its retention.

Retention and deletion of data: The following general deadlines apply to retention and archiving under German law:

• 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents required for their understanding (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 AO, Section 14b Paragraph 1 UStG, Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 HGB).

• 8 years - accounting documents, such as Invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).

• 6 years - Other business documents: commercial or business letters received, copies of the commercial or business letters sent, other documents insofar as they are important for taxation, e.g. E.g. hourly wage slips, company accounting sheets, calculation documents, price labels, but also payroll documents, provided they are not already accounting documents and cash register slips (§ 147 Para. 1 No. 2, 3, 5 in conjunction with Para. 3 AO, § 257 Para. 1 No. 2 and 3 in conjunction with Para. 4 HGB).

• 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights as well as to process related inquiries based on previous business experience and usual industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Start of the deadline at the end of the year: If a deadline does not explicitly start on a specific date and is at least one year, it starts automatically at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships in which data is stored, the event that triggers the deadline is the time when the termination or other termination of the legal relationship comes into effect.

Rights of Data Subjects

Rights of the data subjects under the GDPR: As a 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, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.

• Right to revoke consent: You have the right to revoke your consent at any time.

• Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.

• Right to rectification: In accordance with legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.

• Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to request a restriction of the processing of the data in accordance with the legal requirements.

• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.

• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged violation, if you believe that the processing of your personal data violates the provisions of the GDPR.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers and other cooperation partners (collectively "contractual partners"), to initiate, implement and process contractual relationships and comparable legal relationships. This also includes pre-contractual measures that take place upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfill our main and secondary contractual obligations. This includes the provision of the agreed services, any update and information obligations, the processing of warranty and other service disruptions, the processing of cancellations, terminations of long-term obligations, reversals, refunds and the processing of other contract-related declarations and inquiries. Both one-off contracts and ongoing contractual relationships are covered.

In particular, master data such as name, address and, if applicable, company, contact data such as email address and telephone number, contract and service data such as subject matter of the contract, contract term, order or process number, usage and service data, payment and billing data as well as communication content and history are processed. If necessary, we also process data that is disclosed or transmitted to us in the course of carrying out an order.

In addition, we process the data to protect our rights and to fulfill legal obligations. This includes, in particular, commercial and tax retention obligations, documentation obligations and, if necessary, proof and accountability obligations. In addition, processing is carried out on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security as well as in protecting our business operations and our contractual partners from misuse and threats to data, secrets and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, to the extent that this is necessary for the execution of the contract or to fulfill legal obligations.

Personal data will only be passed on to third parties if this is necessary to fulfill the contract, to carry out pre-contractual measures, to protect legitimate interests or to fulfill legal obligations. We provide separate information about further processing, in particular for marketing purposes, in this privacy policy.

We inform the contractual partners which data is required in individual cases as part of the data collection, for example in online forms through appropriate labeling or in personal contact.

The data will be deleted as soon as it is no longer required for the aforementioned purposes and there are no legal retention requirements. Statutory retention periods, particularly under commercial and tax law, may require longer storage. We delete data that was transmitted as part of a specific order after the order has been completed and any retention periods have expired, provided there are no further legal or contractual obligations to store it.

The legal basis for processing is Article 6 Paragraph 1 Letter b GDPR for the implementation of pre-contractual measures and to fulfill the respective contractual relationship as well as Article 6 Paragraph 1 Letter c GDPR for the fulfillment of legal obligations. To the extent that processing is based on legitimate interests, it is carried out on the basis of Article 6 (1) (f) GDPR. To the extent that processing is based on Article 6 Paragraph 1 Letter f of the GDPR, it is carried out to protect our legitimate interests in proper and efficient business organization, the internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring safe and legally compliant business operations and in preserving our ability to act as a business.

• Types of data processed: inventory data (e.g. full name, home address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g. postal and email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).

• Persons affected: service recipients and clients; interested parties. Business and contractual partners.

• Purposes of processing and legitimate interests: provision of contractual services and fulfillment of contractual obligations; Communication; office and organizational procedures; Organizational and administrative procedures. Business processes and business procedures.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Project and development services: We process the data of our customers and clients (hereinafter referred to as "customers") in order to enable them to select, purchase or commission the selected services or works as well as associated activities as well as their payment and provision or execution or provision.

The required information is marked as such within the framework of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

• Technical services: We process the data of our customers and clients (hereinafter referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works as well as associated activities as well as their payment and provision or execution or provision.

The required information is marked as such within the framework of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. If we receive access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Provision of the Online Offering and Web Hosting

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

• Types of data processed: Usage data (e.g. page views and time spent, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved); Protocol data (e.g. log files regarding logins or the retrieval of data or access times). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Provision of online offerings on our own/dedicated server hardware: To provide our online offerings, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

• Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

• Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of emails (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of Cookies

The term “cookies” refers to functions that store and read information from users’ end devices. Cookies can also be used for various purposes, such as the functionality, security and convenience of online offerings and the creation of analyzes of visitor flows. We use cookies in accordance with legal regulations. If necessary, we obtain the users’ consent in advance. If consent is not necessary, we rely on our legitimate interests. This applies if storing and reading information is essential in order to be able to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

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

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).

• Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and can also declare an objection to the processing in accordance with the legal requirements, including using the privacy settings of their browser.

• Types of data processed: meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).

• Data subjects: Users (e.g. website visitors, users of online services).

• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

• Processing of cookie data based on consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned as part of the consent management solution is obtained. This procedure is used to obtain, record, manage and revoke consent, particularly with regard to the use of cookies and similar technologies that are used to store, read and process information on users' end devices. Within the scope of this procedure, users' consents are obtained for the use of cookies and the related processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option to manage and revoke their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If there is no specific information about the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Registration, Login, and User Account

Users can create a user account. Within the scope of registration, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfillment of obligations. The data processed includes, in particular, login information (username, password and an email address).

Within the scope of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests and those of the users in protecting against misuse and other unauthorized use. In principle, this data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can access processes that are relevant to their user account, such as technical changes, will be informed by email.

• Types of data processed: inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Protocol data (e.g. log files regarding logins or the retrieval of data or access times).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing and legitimate interests: provision of contractual services and fulfillment of contractual obligations; security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Deletion after termination.

• Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Registration with real names: Due to the nature of our community, we ask users to only use our offer using real names. i.e. the use of pseudonyms is not permitted; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

• Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account, ensuring that only you can access your account, even if someone else knows your password. To do this, you must perform another authentication measure in addition to your password (e.g. enter a code sent to a mobile device). We will inform you about the process we use; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

• Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to a legal permission, obligation or consent of the user; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

• No obligation to retain data: It is the users' responsibility to secure their data before the end of the contract if the contract is terminated. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Single Sign-On Login

"Single sign-on" or "single sign-on registration or "authentication" are procedures that allow users to use a user account to log in to a provider of single sign-on procedures (e.g. a social network), including our online offering. The prerequisite for single sign-on authentication is that the user is registered with the respective single sign-on provider and enters the required access data in the online form provided. or are already registered with the single sign-on provider and confirm the single sign-on registration via the button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that we cannot use for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of the authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, there can be different data, usually the email address and the user name. The password entered as part of the single sign-on procedure with the single sign-on provider is neither visible to us nor is it stored by us.

Users are asked to note that the information we store can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually done. Change e.g. the users' email addresses, they must change them manually in their user account with us.

If agreed with the users, we can use the single sign-on registration as part of or before the fulfillment of the contract, if the users have been asked to do so, process it as part of their consent and otherwise use it on the basis of our legitimate interests and the users' interests in an effective and secure registration system.

Should users decide that they no longer want to use the link to their user account with the single sign-on provider for the single sign-on procedure, they must delete this connection within their user account with the single sign-on provider. If users want to delete their data from us, they must cancel their registration with us.

• Types of data processed: inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing and legitimate interests: provision of contractual services and fulfillment of contractual obligations; security measures; Registration procedure. Provision of our online offering and user-friendliness.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Deletion after termination.

• Legal basis: fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Apple Single Sign-On: user login authentication services, providing single sign-on capabilities, identity information management and application integrations; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.

• Google Single Sign-On: User login authentication services, providing single sign-on capabilities, identity information management and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Right to object (opt-out): Settings for the display of advertising: https://myadcenter.google.com/.

Additional notes on passkey management for single sign-on providers:

• Apple (iCloud Keychain): Apple uses the operating system's native key management for managing private keys (iCloud Keychain). This requires an active Apple ID and iCloud Keychain enabled. The private keys are not stored exclusively locally, as is the case with hardware-bound FIDO2 security keys, but are synchronized via Apple's cloud with end-to-end encryption. According to Apple, the company itself cannot access passkey contents in plain text. Cloud-based key management enables cross-device availability on Apple devices and recovery in the event of loss of individual devices. Recovery generally requires the Apple ID password, the device passcode, and a trusted phone number stored in the Apple account. Use on devices from other manufacturers can take place via a QR-code-based sign-in process; as a rule, Bluetooth must be enabled on both devices.

• Google (Google Password Manager): On Android devices and devices with ChromeOS, passkeys are managed through Google Password Manager. The cryptographic key pairs are generated on the device; for synchronization, the private key is stored in encrypted form in Google's account infrastructure. According to Google, synchronization is end-to-end encrypted. This allows passkeys to be made available on additional Android devices linked to the same Google account. In case of device loss, recovery is generally possible if account access and the required verification factors (e.g. the device screen lock code) are available. As with Apple, a smartphone can also be used on third-party computers as an external authenticator for QR-code-based sign-ins; as a rule, Bluetooth must be enabled on both the smartphone and the computer.

Contact and Inquiry Management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring person is processed to the extent that this is necessary to answer the contact request and any requested measures.

• Types of data processed: contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).

• Data subjects: communication partners.

• Purposes of processing and legitimate interests: communication; organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

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

Newsletter and Electronic Notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipient or on the basis of a legal basis. If the content is mentioned when registering for the newsletter, this content is decisive for the user's consent. To register for our newsletter, it is usually sufficient to provide your email address. However, in order to be able to offer you a personalized service, we may ask you to provide your name for a personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the event of an obligation to permanently observe objections, we reserve the right to store the email address in a blacklist (so-called “blocklist”) solely for this purpose.

The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is based on our legitimate interests in an efficient and secure mailing system.

Contents:

Information about us, our services, promotions and offers and security measures emails (2 factor-auth).

• Types of data processed: inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact information (e.g. postal and email addresses or telephone numbers); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved). Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

• Data subjects: communication partners.

• Purposes of processing and legitimate interests: Direct marketing (e.g. via email or post).

• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

• Right to object (opt-out): You can cancel your receipt of our newsletter at any time, i.e. Revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Further information on processing processes, procedures and services:

• Measurement of opening and click rates: The newsletters contain a so-called “web beacons”, i.e. h. a pixel-sized file that is retrieved from our server or its server if we use a shipping service provider when the newsletter is opened. Within the scope of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (Legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Promotional Communication via Email, Post, Fax, or Telephone

We process personal data for the purposes of advertising communication via various channels, such as E-mail, telephone, post or fax, can be carried out in accordance with the legal requirements.

The recipients have the right to revoke their consent at any time or to object to the advertising communication at any time free of charge using the contact option mentioned above.

After revocation or objection, we store the data required to prove previous authorization to contact or send you up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of possible defense against claims. Based on the legitimate interest in permanently observing the user's revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

• Types of data processed: inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact details (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation).

• Data subjects: communication partners.

• Purposes of processing and legitimate interests: direct marketing (e.g. via email or post); Marketing. Sales promotion.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Web Analytics, Monitoring, and Optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite them to reuse it. It is also possible for us to understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized into a usage process, can be created for these purposes and information can be stored in a browser or in a device and then read out. The information collected includes, in particular, websites visited and elements used there, as well as technical information, such as the browser used, the computer system used and information about times of use. If users have agreed to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

In addition, the users' IP addresses are stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

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

• Types of data processed: Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, people involved).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing and legitimate interests: reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).

• Security measures: IP masking (pseudonymization of the IP address).

• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed within one or different usage processes, which search terms they have used, which they have accessed again or which have interacted with our online offering. The time of use and its duration are also stored, as are the sources of the users who refer to our online offering and technical aspects of their devices and browsers.

Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the city's derived latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible and are not used for any other purposes. When Google Analytics collects metrics, all IP queries are performed on EU-based servers before passing traffic to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and the data processed).

Presence on Social Networks (Social Media)

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

We would like to point out that user data can be processed outside the European Union. This can result in risks for users because, for example, it could make it more difficult to enforce user rights.

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policys and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of the rights of those affected, we would also like to point out that these can most effectively be asserted with the providers. Only the latter have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and posts as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing and legitimate interests: communication; Feedback (e.g. collecting feedback via online form). Public relations.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Instagram: social network, allows you to share photos and videos, comment and favorite posts, send messages, subscribe to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).

• Facebook pages: Profiles within the social network Facebook - The person responsible, together with Meta Platforms Ireland Limited, is responsible for collecting and transmitting data from visitors to our Facebook page ("Fanpage"). This includes, in particular, information about user behavior (e.g. content viewed or interacted, actions taken) as well as device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further information can be found in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyzes via the “Page Insights” service, which provide information about how people interact with our site and its content. The basis for this is an agreement with Facebook ("Information on Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of the rights of those affected. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore address requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).

• LinkedIn: Social network - We, together with LinkedIn Ireland Unlimited Company, are responsible for the collection (but not further processing) of visitor data, which is used to create the "page insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's data protection information: https://www.linkedin.com/legal/privacy-policy.

We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of those affected (i.e. users can, for example, address requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of the data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of the data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

• X: Social network; Service Provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.

• YouTube: social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Right to object (opt-out): https://myadcenter.google.com/personalizationoff.

Data Protection Information for Whistleblowers

In this section you will find information about how we handle data from whistleblowers and affected and involved parties as part of our whistleblower process.

Legal basis (Germany): To the extent that we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for the processing is Article 6 Paragraph 1 Sentence 1 Letter c) GDPR and, in the case of special categories of personal data, Article 9 Paragraph 2 Letter g) GDPR, Section 22 BDSG, each in conjunction with Section 10 HinSchG. This refers to the obligation to set up and operate an internal whistleblower reporting center, to fulfill its legal tasks and, if the data collected in the reporting process is used.

Types of data processed: We may collect various data as part of the receipt and processing of tips and in the subsequent whistleblowing process. These include in particular the data provided by a whistleblower, such as: name, contact details and whereabouts of the person giving the tip, names and details of possible witnesses or people affected by the tip, names and details of the people against whom the tip is directed, data about the alleged misconduct, further relevant details.

Special Categories of Personal Data: We may collect special types of personal data in the course of our activities, particularly when provided by a whistleblower. This includes: Health-related data of a person, data on racial or ethnic origin.

Use of our online forms: Please note that it is possible to submit information anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called 'incognito mode' of your browser. Here's how you can open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

Providing names: You have the option of submitting information anonymously. However, unless prohibited by national legislation, we recommend providing your name and contact details. This enables us to investigate the report more effectively and, if necessary, to contact you directly.

Provision of data to third parties: Data related to the information provided will only be passed on to third parties by us under certain circumstances. This happens either a) if you have given us your express consent to do so, or b) if there is a legal obligation to pass on the data. Possible third parties include public authorities, governmental, regulatory or tax authorities if the disclosure is necessary to comply with a legal or regulatory obligation. We may also engage lawyers and other specialist advisors as permitted by law. They have the authority to investigate suspected misconduct and take necessary action following an investigation, such as initiating disciplinary or legal proceedings. In addition, service providers carefully selected and monitored by us may receive data for these purposes (e.g. operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations as part of order data processing.

Data retention and deletion: Personal data will only be processed for as long as necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted.

Technical and organizational measures: We have implemented the necessary contractual, technical and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes.

• Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number. Employee data (information about employees and other people. Contact details (e.g. postal and email addresses. Content data (e.g. textual or pictorial messages and posts as well as the information relating to them, such as information on authorship). Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used).

• Data subjects: Employees (e.g. employees, applicants, temporary workers and other third persons. Whistleblower.

• Purposes of processing and legitimate interests: whistleblower protection.

• Retention and deletion: Deletion as specified in the “General information on data storage and deletion” section.

• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out 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 for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

Supervisory authority responsible for us:

https://www.ldi.nrw.de

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are intended primarily to provide understanding.

• Employees: Employees are people who are employed, be it as employees, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It involves the employer's obligation to pay remuneration to the employee while the employee performs his or her work. The employment relationship includes various phases, including the justification in which the employment contract is concluded, the implementation in which the employee carries out his work activity and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information that relates to these people and is in the context of their employment. This includes aspects such as personal identification information, identification numbers, salary and banking information, working hours, vacation entitlements, health information and performance reviews.

• Inventory data: Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This information may include, but is not limited to, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear attribution and communication.

• Content data: Content data includes information that is generated in the course of creating, editing and publishing all types of content. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates

• Contact details: Contact details are essential information that enables communication with people or organizations. They include, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.

• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, provenance, and structure of other data. They can include information about file size, creation date, author of a document and change histories. Communication data records the exchange of information between users across various channels, such as email traffic, call logs, social network messages and chat histories, including the people involved, timestamps and transmission routes. Procedural data describes the processes and operations within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.

• Usage Data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, what features they prefer, how long they spend on certain pages, and the paths they take to navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings

• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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 (e.g. cookie) or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data, which consists in using these personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) B. interests in certain content or products, click behavior on a website or whereabouts). Cookies and web beacons are often used for profiling purposes.

• Log Data: Log data is information about events or activities logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, monitor security, or create performance reports.

• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can determine the behavior or interests of visitors in certain information, such as content of websites. With the help of reach analysis, operators of online offers can e.g. recognize at what time users visit your websites and what content they are interested in. This allows you, for example, B. adapt the content of the websites better to the needs of your visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyzes of the use of an online offering.

• Controller: The “controller” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.

• Processing: “Processing” means any operation or series of operations carried out on personal data, whether or not by automated means. The term is wide-ranging and includes practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.

• Contract data: Contract data is specific information related to the formalization of an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, extension options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims and resolving disputes.

• Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for electronic commerce, online banking and any other form of financial transaction. They include details such as credit card numbers, bank details, payment amounts, transaction details, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.