Privacy Policy

This translation is for informational purposes only. In the event of any discrepancies between this and the German version, the German version shall prevail.

This Privacy Policy informs you about the nature, scope, and purpose of the processing of personal data ("Data") within our software products and services ("Products and Services") and the associated programs, apps, functions, and content, as well as our online presence with all websites and all our social media profiles ("Online Offerings").

We attach great importance to data protection. The collection and processing of your personal data is carried out in compliance with applicable data protection regulations, in particular the General Data Protection Regulation (GDPR).

"Personal data" is all 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/ID, location data, an online identifier (e.g., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually all data handling.

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

Responsible

The controller responsible for the collection, processing, and use of your personal data within the meaning of Art. 4 No. 7 GDPR is

Bettysoft Solutions UG (limited liability)
Hof Güldenwerth 23
42857 Remscheid
Germany

Represented by: Frederick Bettray

Email: legal@bettysoft.de
Phone: +49 (0) 2191 5989980
https://www.bettysoft.de/imprint/

If you wish to object to the collection, processing, or use of your data by us in accordance with this privacy policy in whole or in relation to individual measures, you can address your objection to the controller. You can save and print this privacy policy at any time.

Data Protection Officer:
According to Section 38 of the German Federal Data Protection Act (BDSG) in conjunction with Article 37 of the GDPR, the appointment of a data protection officer is currently not required. Should this change (e.g., due to growth/data protection obligation), we will immediately appoint a data protection officer and update this notice.
For all data protection-related inquiries, please contact our data protection contact at: legal@bettysoft.de.

Purposes for which personal data are processed

Hosting

We host our website with Strato. When you visit our website, we automatically collect data and information from your device's system and store it in so-called server log files.

Data collected and processed:
- Technical information such as the IP address,
- Device information,
- User behavior relevant for error analysis,
- Website visit data,
- Browser information,
- Log data,
- Cookies.

Data subjects:
- Users of our online offerings.

Legal basis:
- Legitimate interest (technical provision or use & security of the website, e.g., detection/defense against attacks) based on Art. 6 (1) (f) GDPR.

Involved processor:
- Strato GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany.
We have concluded a data processing agreement (DPA) with Strato in accordance with Art. 28 GDPR. This agreement is available for inspection upon request.

Retention period:
- Server log files: 7 days.

Contact and inquiry management

When you contact us (e.g., by mail, 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 person contacting you will be processed to the extent necessary to respond to the contact inquiries and any requested actions.

User information may be stored in a customer relationship management system ("CRM system") or similar inquiry organization.

Data collected and processed:
- Inventory data (e.g., last name, first name, home address, contact information, customer number, etc.),
- Contact data (e.g., postal and email addresses or telephone numbers),
- Content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation),
- Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions),
- Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved).

Data subjects:
- Communication partners.

Legal basis:
- Legitimate interests (Art. 6 (1) (f) GDPR),
- Contractual fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Purposes of processing:
- Communication,
- Organizational and administrative procedures, Feedback (e.g., collecting feedback via online form), Provision of our online services and user-friendliness.

Further information on processing procedures, methods, and services:

Data collected and processed (by post):
- Inventory data (last name, first name, residential address),
- Contact data (postal address),
- Content data resulting from your letter itself,
- Meta, communication, and procedural data (time information).

Data collected and processed (by telephone):
- Inventory data (last name, first name, residential address),
- Contact data (postal address, email address, telephone number),
- Content data resulting from your telephone call with us,
- Meta, communication, and procedural data (time information, transcripts of the telephone call).

We only transcribe telephone calls with your prior consent for documentation and quality assurance purposes (Art. 6 (1) (a) GDPR).

Data collected and processed (email): - Contact details (email address),
- Content data resulting from your email itself (possibly also attachments),
- Meta, communication, and procedural data (IP address, time stamp, identification numbers, persons involved).

Data collected and processed (contact form):
- Contact details (email address),
- Content data resulting from your message itself (possibly also attachments),
- Meta, communication, and procedural data (IP address, time stamp).

Legal basis:
- The legal basis for the processing of personal data described here is Art. 6 (1) (f) GDPR. Our legitimate interest is to offer you the opportunity to contact us at any time and to answer your inquiries.

Involved processor:
- Strato GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany.
We have concluded a data processing agreement (DPA) with Strato in accordance with Art. 28 GDPR. This agreement is available for inspection upon request.

Retention period:
- Personal data will only be processed for as long as necessary to process the contact request and will then be deleted.

We ask you not to submit any particularly sensitive categories of personal data when contacting us. These categories include, among others, the following data:
- Ethnic origin,
- Political opinions,
- Religious or ideological beliefs,
- Trade union membership,
- Genetic data,
- Biometric data,
- Health data,
- Data regarding sex life or sexual orientation.

Online appointment scheduling

You can schedule an appointment with us on our website.

Data collected and processed:
- Inventory data (last name, first name, home address),
- Contact details (email address, telephone number),
- Content data (textual messages and related information, such as authorship or time of creation),
- Meta, communication, and process data (IP address, time information).

Data subjects:
- Users of our online appointment scheduling service.

Legal basis:
- Consent of the data subject based on Art. 6 (1) (a) GDPR.

Further information:
We ask you not to submit any particularly sensitive categories of personal data when scheduling an appointment online. These categories include, among others, the following data:
- Ethnic origin,
- Political opinions,
- Religious or ideological beliefs,
- Trade union membership,
- Genetic data,
- Biometric data,
- Health data,
- Data regarding sex life or sexual orientation.

You can avoid having your data collected by not using the online appointment booking service.

User account (Bettysoft Account)

You can create a user account ("Bettysoft Account") to access protected content.

Data collected and processed:
- Email address, password (hashed),
- address details (last name, first name, street, place of residence, zip code),
- bank details (account holder, IBAN, BIC),
- time stamp of registration & last login.

Data subjects:
- Users of our online services, in particular the Bettysoft Account.

Legal basis:
- Art. 6 (1) (b) GDPR (performance of contract),
- Art. 6 (1) (f) GDPR (security & prevention of misuse).

Retention period:
- As long as the account is active.
- After deletion: within 30 days, unless statutory retention periods conflict.

Payment methods

Within the framework of contractual and other legal relationships, due to legal obligations, or otherwise based on our legitimate interests, we offer data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other service providers (collectively, "payment service providers").

The data processed by the payment service providers includes inventory data, such as name and address, bank details, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum, and recipient-related information. This information is required to process the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.

The terms and conditions and privacy policy of the respective payment service providers apply to payment transactions and are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.

Data collected and processed:
- Inventory data (e.g., last name, first name, home address, contact information, customer number, etc.),
- Payment data (e.g., bank details, invoices, payment history),
- Contract data (e.g., contract subject matter, term, customer category),
- Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions),
- Meta, communication, and process data (e.g., IP addresses, time information, identification numbers, persons involved).

Data subjects:
- Service recipients and clients,
- business and contractual partners,
- prospective parties.

Legal basis:
- Art. 6 (1) (b) GDPR (contractual performance and pre-contractual inquiries),
- Art. 6 (1) (f) GDPR (legitimate interests, in particular fraud prevention).

Security measures for third-country transfers:
- Standard Contractual Clauses (SCC) of the EU Commission + Transfer Impact Assessment (TIA).

Storage period:
- Payment data in accordance with statutory retention periods (10 years, Section 147 of the German Fiscal Code (AO)).

Further information on processing procedures, methods, and services:
PayPal: Payment services (technical connection of online payment methods) (e.g., PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

Analysis of user behavior

Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can, for example, identify when our online offering or its functions or content are most frequently used, or encourage reuse. It also enables us to understand which areas require optimization.

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

Unless otherwise stated below, profiles—data summarized for a usage process—may be created for these purposes, and information may be stored in a browser or device and then read out. The data 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 on usage times. If users have consented to the collection of their location data with us or with the providers of the services we use, the processing of location data is also possible.

In addition, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective processes.

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

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

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

Purposes of processing:
- Reach measurement (e.g., access statistics, recognition of recurring visitors),
- Profiles with user-related information (creation of user profiles),
- Remarketing.

Retention and deletion:
- Deletion in accordance with the information 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 bases:
- Consent (Art. 6 (1) (a) GDPR),
- Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods, 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 more usage processes, which search terms they used, accessed these again, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and the technical aspects of their devices and browsers.
Pseudonimous profiles of users are created with information from the use of various devices; cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide coarse geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) (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; Contract processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff; Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
- Matomo: Matomo is a software used for web analysis and audience measurement purposes. When Matomo is used, cookies are generated and stored on the user's device. The user data collected as part of the use of Matomo is processed solely by us and not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Legal basis: Consent (Art. 6 (1) (a) GDPR); Deletion of data: The cookies are stored for a maximum period of 13 months.

Presences in social networks (social media)

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

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

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

For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.

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

Data collected and 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 related information, such as authorship or time of creation),
- Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).

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

Legal basis:
- Legitimate interests (Art. 6 (1) (f) GDPR).

Purposes of processing:
- Communication,
- Feedback (e.g., collecting feedback via online form),
- Public relations.

Retention period:
- Deletion in accordance with the information in the "General information on data storage and deletion" section.

Further information on processing procedures, methods, and services:
Instagram: Social network, enables sharing photos and videos, commenting and favorite posts, sending messages, and subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (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 - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As described in the Facebook Data Policy under "How do we use this information?" As explained above, Facebook also collects and uses information to provide analytics services, so-called "Page Insights," to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook ("Information about Page Insights," https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to the parent company 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 (1) (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 collecting (but not further processing) visitor data to create “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. We also collect details about the devices used, such as IP addresses, operating systems, browser types, 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. Information about LinkedIn’s processing of user data can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which 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 competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (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); Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Further information

Rights of data subjects

Right to information
You have the right to request confirmation as to whether data concerning you is being processed and to access this data, as well as further information and a copy of the data, in accordance with Art. 15 GDPR.

Right to rectification
According to Art. 16 GDPR, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be rectified.

Right to erasure
According to Art. 17 GDPR, you have the right to have personal data processed by us erased – where this is legally permissible.

Right to restriction of processing
According to Art. 18 GDPR, you have the right to request that we restrict the processing of your personal data under certain circumstances.

Right to data portability
According to Art. 20 GDPR, you have the right to receive the data concerning you that you have provided to us in a structured, common, and machine-readable format, in accordance with the statutory requirements, or to request that it be transmitted to another controller.

Right to object
In accordance with Art. 21 GDPR, you have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.

Right to withdraw consent
You have the right to withdraw consent granted at any time in accordance with Art. 7 (3) GDPR.

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

Protection of personal data

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

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to threats to data. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

IP address shortening: If IP addresses are processed by us or by the service providers and technologies we use, and the processing of a full IP address is not required, the IP address is shortened (also known as "IP masking"). The last two digits, or the last part of the IP address after a period, are removed or replaced with placeholders. The purpose of shortening the IP address is to prevent or significantly complicate the identification of a person based on their IP address.

Securing online connections with 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, the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Data transfer

We will only share your personal data with third parties if required by law, if necessary to provide our services, or if you have consented to the sharing. We will never sell your data to third parties without your express consent.
Data may be shared, where necessary, with the following categories of recipients:
- Processors named in this Privacy Policy,
- Banks and payment service providers (payment processing),
- Shipping service providers (shipping goods and invoices),
- Tax consultants (accounting and annual financial statements),
- Debt collection agencies (collecting debts),
- Lawyers (asserting legal claims).

International data transfers

Transfer of data to the USA and the Data Privacy Framework
We would like to point out that the EU Commission issued an adequacy decision on the EU-US Data Privacy Framework pursuant to Art. 45 (1) GDPR on July 10, 2023. Accordingly, organizations and companies (as data importers) in the USA that are registered in a public list as part of the Data Privacy Framework self-certification offer an adequate level of protection for data transfers. This therefore represents a valid legal basis for the use of certified US services. For all purposes mentioned in this Privacy Notice that use services from US providers with an adequate level of protection, the legal basis is "Data Privacy Framework." You can research whether a service provider is certified directly on the Data Privacy Framework website.

If a provider is not certified by the Data Privacy Framework, this will be explicitly mentioned in the respective purpose, and a valid alternative legal basis will be provided.

Standard Contractual Clauses
To enable data transfers to countries without an adequacy decision, the EU Commission has created model contracts (standard contractual clauses). These standard contractual clauses oblige contracting parties to maintain a level of data protection comparable to that in the EU. These contract texts are available on the European Union website. Standard contractual clauses are abbreviated to "SCC" in English.

Use of cookies

The term "cookies" refers to functions that store and retrieve information from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online services, as well as creating analytics of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and retrieving information is essential to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be revoked at any time. We provide clear information about the scope of this consent and which cookies are used.

Notes on legal bases under data protection law:
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 respective services and procedures.

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

- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g., browser or mobile application).
- Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using cookies can 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 also object to processing in accordance with legal requirements, including through the privacy settings of their browser.
- Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Users (e.g., website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Consent (Art. 6 (1) (a) GDPR).

Further information on processing processes, procedures, and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers specified within the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, particularly with regard to the use of cookies and similar technologies used to store, read, and process information on users' devices. Within the scope of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing methods and providers specified in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are stored to avoid repeated requests and to be able to provide evidence of consent in accordance with legal requirements. The data is stored 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 no specific information is available about the providers of consent management services, the following general information applies: The consent is stored for a period of up to two years. A pseudonymous user identifier is created which is stored together with the time of consent, information on the scope of the 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 (1) (a) GDPR);

You can specify how the web browser handles cookies and local storage, which storage operations are permitted or rejected, and for how long the data processing takes place in the web browser settings.

General information on data storage and deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose retention is necessary for legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

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

If multiple retention periods or deletion periods are specified for a given date, the longest period always applies. Data that is no longer retained for the originally intended purpose but due to legal requirements or other reasons is only processed for the reasons that justify its retention.

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

- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).
- 8 years - Accounting documents, such as invoices and cost receipts (Section 147 (1) Nos. 4 and 4a in conjunction with (3) Sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
- 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents relevant for tax purposes, e.g., timesheets, operating statements, calculation documents, price labels, but also payroll documents, provided they are not already accounting documents, and cash register slips (Section 147 (1) Nos. 2, 3, and 5 in conjunction with Section 3 of the German Fiscal Code (AO), Section 257 (1) Nos. 2 and 3 in conjunction with Section 4 of the German Commercial Code (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 common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 195 and 199 of the German Civil Code).

Time limit begins at the end of the year: If a time limit does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the date on which the termination or other termination of the legal relationship takes effect.

Revocation of consent given

If you have given your consent to the processing of your personal data for a specific purpose based on Art. 6 (1) (a) GDPR, you can withdraw this consent at any time (revocation). The legality of the processing of your personal data prior to the revocation will not be affected by this revocation.

Mandatory provision of data and consequences of non-provision when visiting the website

The provision of personal data for visiting our website is neither legally nor contractually required. Failure to provide your personal data is possible if you do not visit this website. Failure to provide your personal data will result in certain functions on our website not being available.

Changes and updates

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt this 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 of 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.

All changes will be published on this page with an updated modification date.
Date of publication of the current version: August 21, 2025

Appendix 1 to the Data Processing Agreement - Approved Subcontractors / Other Processors