Privacy Policy

Table of contents

• Preamble
• Responsible
• Processing overview
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• Data deletion
• Rights of the data subjects
• Cookies use
• Business services
• Providers and services used in the course of business
• Payment method
• Provision of the online offer and web hosting
• Registration, login and user account
• Community functions
• Single sign-on login
• Blogs and publication media
• Contact and request management
• Newsletter and electronic notifications
• Promotional communication via e-mail, mail, fax or telephone
• Web analysis, monitoring and optimization
• Online marketing
• Presence in social networks (social media)
• Plugins and embedded functions and content
• Management, organization and auxiliary tools
• Definitions

Responsible

Applytip

Ritterstraße 8
33602 Bielefeld

E-mail address: 

info@applytip.com

Imprint: 

https://www.applytip.com/imprint

Processing overview

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.
• Payment details.
• Contact details.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and procedural data.

Categories of affected persons

• Customers.
• Interested parties.
• Communication partner.
• Users.
• Business and Contractual Partners.

Processing purposes

• Provision of contractual services and fulfillment of contractual obligations.
• Contact requests and communication.
• Safety measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organizational procedures.
• Conversion measurement.
• Managing and responding to inquiries.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Application Procedure.
• Provision of our online offer and user-friendliness.
• Information Technology Infrastructure.

Relevant legal bases

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

• Consent (Art. 6 (1) p. 1 lit. a) DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
• Contract performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) - Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request.
• Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on applicability DSGVO and Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (DSGVO). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of its application.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, 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.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS/SSL encryption (https): To protect user data transmitted through our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing Internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) appears in the URL when a website is secured by an SSL/TLS certificate.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where there is consent from the data subjects or legal permission.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 DSGVO), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular by standard contractual clauses (Art. 46(2)(c) DSGVO), explicit consent or in the case of contractual or legally required transfer (Art. 49(1) DSGVO). In all other respects, we will inform you of the basis for third-country transfers in the case of individual third-country providers, with the adequacy decisions taking precedence as the basis. Information on third country transfers and existing adequacy decisions can be found in the EU Commission's information offer: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as safe within the framework of the adequacy decision of July 10, 2023. The list of certified companies as well as further information about the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/. We will inform you in the privacy notices which service providers we use are certified under the Data Privacy Framework.

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person. Our data protection notices may also contain further details on the retention and deletion of data, which take priority for the respective processing operations.

Rights of the data subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
• Right of revocation for consents: You have the right to revoke any consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
• Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another controller.
• Complaint to 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, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.

Cookies use

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows. 

Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the telemedia service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and will contain the information regarding the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of storage duration, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her end device (e.g. browser or mobile app).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (so-called "opt-out"): Users can revoke the consents they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

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

Further guidance on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data are required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins with the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

• Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
• Affected persons: Customers; prospective customers. Business and contractual partners.
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Management and response to requests.
• Legal basis: Contract fulfillment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Customer account: Customers can create an account within our online offer (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the termination date, unless they are kept for other purposes than the provision in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order transactions or invoices). It is the responsibility of the customers to secure their data upon termination of the customer account; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as "users") in order to be able to provide our contractual services to them as well as on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion 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; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Providers and services used in the course of business

As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, "services") in compliance with legal requirements. Their use is based on our interests in a proper, lawful manner and scope.

• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of contract, term, customer category.
• Affected persons: Customers; prospective customers; users (e.g. website visitors, users of Business and contractual partners.
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Payment method

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy policy of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

• Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status).
• Affected persons: Customers. Interested parties.
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third country transfers: EU-US Data Privacy Framework (DPF).

Provision of the online offer and web hosting

We process the users' data in order 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 terminal device.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).). Security measures.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, 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 may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event 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 p. 1 lit. f) DSGVO). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
• E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, 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 not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Content Delivery Network: We use a "content delivery network" (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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Using Webflow for our Online Offer

In the provision of our online services, we utilize Webflow, a platform dedicated to website design and development. When interacting with our online offer built on Webflow, users should be aware of the following:

• Nature of Relationship with Webflow: If you engage with our website built through Webflow, it's essential to understand our relationship with Webflow. While we (the website owner) act as the "controller" of your data, determining how and why your personal data is processed, Webflow acts as the "processor." This means Webflow processes your data based on our instructions.
• Data Storage & International Transfers: Webflow stores data, including data from our users, in the United States. This data storage might involve transferring your personal data out of Europe. To legally process and transfer this data, Webflow employs the European Union’s standard contractual clauses. While Webflow remains self-certified under the E.U. – U.S. Privacy Shield, they still honor the Privacy Shield Principles despite its invalidation in 2020. Webflow consistently keeps track of international data transfer developments and is committed to a privacy-by-design approach for its customers and end users.
• Security Measures by Webflow: Security is paramount for Webflow. They ensure the data they manage is encrypted both in transit and at rest. Webflow possesses a SOC 2 certification, emphasizing their dedication to a robust security program. For a more in-depth overview of Webflow’s security measures, users can visit their security center.
• Your GDPR Rights: As an end user of our online service, the GDPR grants you several rights concerning your personal data. This includes rights like data access, rectification, erasure ("right to be forgotten"), data portability, and more. However, if you wish to exercise these rights, it's important to approach us directly, as Webflow, being the processor, cannot honor these requests independently.
• CCPA Considerations: For users who are residents of California, the California Consumer Privacy Act (CCPA) also confers certain rights about personal data. These rights mirror those of the GDPR to a significant extent. Similar to the GDPR, if California residents wish to exercise their CCPA rights, they should approach us directly, as Webflow will not be able to independently respond to such requests.

To stay updated with Webflow's privacy practices and any related changes, users are encouraged to refer to Webflow’s official documentation and privacy resources. As always, our commitment is to ensure a transparent and secure environment for all our users.

Integration with Make.com (formerly Integromat)

In our ongoing efforts to provide you with the best possible online experience, we utilize the services of Make.com (formerly known as Integromat) for certain data processing operations. Make.com offers an advanced automation and integration platform that helps streamline our processes and enhance the functionality of our online services.

• European Infrastructure Usage: It's important to note that when we engage with Make.com, we exclusively utilize their European infrastructure for data processing. This ensures that any data exchanged or processed through Make.com remains within the European Economic Area (EEA), complying with European data protection standards and regulations.
• Make.com operates in accordance with the Celonis privacy notice, which outlines their data handling practices and privacy policies. You can refer to their privacy notice for more details on how Make.com processes and protects your personal data.
• By leveraging Make.com's services, we aim to enhance the efficiency, reliability, and security of our online services while ensuring compliance with data protection regulations within the EEA.

For any questions, concerns, or requests related to your personal data, including its processing through Make.com, please contact us at privacy@make.com. We are committed to safeguarding your privacy and providing transparency regarding our data processing activities.

Use of Airtable for Enhancing Our Services

In our commitment to provide you with top-tier online services, we have integrated the services of Airtable into our platform. Airtable is a tool we trust for its robust approach to privacy and security. As we strive for excellence in user experience, your data's security remains our paramount concern.Being in compliance with the General Data Protection Regulation (GDPR), Airtable reinforces our commitment to preserving the privacy rights of our European users. This also ensures that we are in line with the rigorous guidelines set for companies processing personal data.

For specifics:

• Types of data processed: While using our online services, be assured that data such as usage details, communication specifics, and content data are handled with utmost care.
• Server Information: The data processed through Airtable is stored on servers located in the US, specifically on US-based AWS servers (US-East-1).

Our use of Airtable is grounded in our legitimate interests to offer you an enhanced online experience and to maintain the technological infrastructure that supports our services. This is in accordance with Art. 6 para. 1 p. 1 lit. f) DSGVO.

For a deeper dive into how Airtable prioritizes data privacy and to acquaint yourself with their detailed privacy policy, you're welcome to visit https://airtable.com/privacy.

Integration of Memberstack for Membership Services

In our continuous endeavor to provide a seamless and enhanced online experience, we have incorporated services from Memberstack, Inc., a reputable company organized under the laws of the State of Delaware, USA. Memberstack is committed to upholding the highest standards of data protection and plays a pivotal role in facilitating our membership functionalities.

• Types of data processed: The integration involves processing member-specific data which might include personal details, subscription preferences, usage statistics, and other relevant data points to ensure smooth membership experience.
• Data subjects: Members and users opting for or interacting with membership functionalities.
• Purposes of processing: Membership management, authentication, personalization of user experience, and ensuring robust security measures for members.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Highlights of Memberstack’s GDPR Compliance:

• Storage Location: Memberstack hosts its services with Amazon Web Services with data storage located in the United States.
• Data Security: Memberstack employs high-security and encryption techniques when processing personal information and adheres to both local and international data protection standards.
• Transfer of Data: Though Memberstack stores all data in the United States, the GDPR does not mandate EU data to remain within the European Union. Memberstack’s Data Processing Addendum, alongside the European Union’s Model Clauses (Standard Contractual Clauses), ensures compliance for EU personal data transfers outside of the EU. Any cross-border transfer of personal data is subject to rigorous transfer impact assessments to evaluate and mitigate risks.
• Data Residence and Future Plans: Currently, all Memberstack data resides in the United States. However, there is potential for offering regional storage within the EU in future iterations.

For more in-depth understanding and any queries about how Memberstack processes data in compliance with GDPR and other relevant regulations, we encourage you to reach out directly to Memberstack at team@memberstack.com. Furthermore, you can also refer to their detailed policies and security practices on their official website.

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

Within the scope of the use of our registration and login functions as well as 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 as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes.

• Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); content data (e.g., entries in online forms); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; management and response to requests. Provision of our online offer and user friendliness.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Registration with clear name: Due to the nature of our community, we ask users to use our offer only by using clear names. I.e. the use of pseudonyms is not permitted; Legal basis: Contract fulfillment and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Users' profiles are not public: Users' profiles are not publicly visible or accessible.

Community functions

The community functions provided by us allow users to enter into conversations or other exchanges with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.

• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations. Security measures.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• Storage of data for security purposes: User contributions and other input are processed for the purposes of the community and conversation functions and, subject to legal obligations or legal permission, are not released to third parties. An obligation to surrender may arise in particular in the case of illegal contributions for the purposes of legal prosecution. We point out that in addition to the content of the contributions, their time and the IP address of the user are stored. This is done in order to be able to take appropriate measures to protect other users and the community; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Right to delete content and information: The deletion of contributions, content or information of users is permissible after proper consideration to the extent necessary insofar as there are concrete indications that they represent a violation of legal rules, our specifications or the rights of third parties; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
• Protection of own data: Users decide for themselves what data they disclose about themselves within our online offering. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and to disclose personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect access data very particularly and use secure passwords (i.e., above all, character combinations that are as long and random as possible); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Single sign-on login

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

Authentication takes place directly with the respective single sign-on provider. In the course of such authentication, we receive a user ID with the information that the user is logged in under this user ID at the respective single sign-on provider and an ID that cannot be used by us 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 during 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, this can be different data, usually the e-mail 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 their details stored with us may be automatically matched with their user account with the single sign-on provider, but that this is not always possible or actually occurs. If, for example, the users' e-mail addresses change, they must change them manually in their user account with us.

We may use single sign-on login, if agreed with users, as part of or prior to contract performance, where users have been asked to do so, process it as part of consent, and otherwise use it based on the legitimate interests of us and the interests of users in an effective and secure login system.

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

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures. Registration procedure.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Single-Sign-On: Authentication service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.google.de; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations; feedback (e.g. collecting feedback via online form). Provision of our online offer and user friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Contact and request management

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

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. web pages visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Affected persons: Communication partners.
• Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO). Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
• HubSpot: Customer management as well as process and sales support with personalized customer care with multi-channel communication, i.e. management of customer inquiries from various channels as well as with analysis and feedback functions; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents: 

Information about us, our services, promotions and offers.

• Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time data, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
• Affected persons: Communication partners.
• Purposes of processing: direct marketing (e.g. .by e-mail or postal mail).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Option to object (opt-out): You can cancel the 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 otherwise use one of the above contact options, preferably e-mail, for this purpose.

Further guidance on processing operations, procedures and services:

• Measurement of opening and click-through rates: The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the evaluations to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.The measurement of opening rates and click rates as well as the storage of the measurement results in the profiles of the users ;‍
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
• HubSpot: Email sending and automation services; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy; Order processing agreement: https://legal.hubspot.com/dpa. Basis third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.hubspot.com/dpa).

Promotional communication via e-mail, mail, fax or telephone

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, name).

• Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
• Affected persons: Communication partners.
• Purposes of processing: direct marketing (e.g. .by e-mail or postal mail).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Web analysis, monitoring and optimization

Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can see, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization. 

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

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. 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 on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, we do not store any clear user data (such as e-mail addresses or names) for the purposes of web analysis, A/B testing and optimization, but rather pseudonyms. This means that we, as well as 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 purposes of the respective procedures.

• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement:
  https://business.safety.google/adsprocessorterms. Basis for third country transfers: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).

Use of Segment for Data Processing and Compliance with GDPR

We utilize Segment, a platform that assists us in processing customer data, ensuring the smooth management and integration of our data analytics operations. Segment has undertaken stringent measures to ensure compliance with the European Union's General Data Protection Regulation (GDPR). As of May 25, 2018, Segment has made sure its practices align with GDPR's requirements. Here are the pertinent aspects of how we employ Segment:

• GDPR Compliance: Segment has not only updated its operations to be GDPR compliant but also aids businesses like ours to easily adhere to the GDPR. Segment acts mainly as a data processor, helping us process our customer data. As data controllers, we are responsible for collecting end-user data and determining the methods and reasons for its processing.
• Data Processing Agreement (DPA) and Standard Contractual Clauses (SCCs): Segment offers a Data Processing Agreement (DPA) that reflects GDPR requirements, especially concerning data transfers outside the European Union. This agreement is crucial for our commitment to data privacy. Segment's DPA has already been incorporated into their Terms of Service, ensuring compliant data transfer and storage outside the EU. For more comprehensive data protection, the Standard Contractual Clauses (SCCs) apply, especially for international data transfers. Despite challenges like the invalidation of the Privacy Shield for data transfers between the EU and the USA, the use of SCCs has been reaffirmed as a valid data transfer method, ensuring uninterrupted service provision from Segment to its EU clientele.
• Support for Data Subject Rights: Segment has implemented product capabilities that assist in compliance when users demand the deletion or suppression of their data.
• Note on Data Protection: It's important for us and our users to understand the various facets of the GDPR and its implications. As data controllers, we ensure that all data collection and processing adheres to GDPR principles, such as lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, confidentiality, and accountability.

For further details on Segment's GDPR compliance and data protection practices, you can refer to their official website and policy documentation. If you have concerns or queries related to data processing or how Segment aids our services in GDPR compliance, feel free to reach out.

Use of Hotjar for Web Analysis and Optimization

We use Hotjar to enhance our web analysis and optimization practices. Hotjar is a tool designed to understand the online behavior and feedback of website users. Their commitment to GDPR ensures that user data is handled with care and in compliance with European data protection standards.

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Through Hotjar, we aim to offer improved user experiences by understanding how visitors interact with our online offering. This service offers functionalities like heatmaps, session recordings, and surveys, amongst others. Notably, Hotjar has built-in measures to ensure user anonymity, such as the automatic suppression of all user keystrokes by default.

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• Key compliance measures undertaken by Hotjar include:
• Appointment of a Data Protection Officer
• Revision of their Data Protection Agreement to align with GDPR requirements
• Implementation of features like Suppression Controls, Visitor Lookup, and Feedback Consent Controls to safeguard user data
• Provisions to address requests related to user rights for accessing personal data stored within our Hotjar account

Types of data processed through Hotjar: Usage data (e.g., interactions with our website, feedback).

• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: User behavior analysis, website optimization, and feedback collection.
• Security measures: Anonymity measures like suppressing user keystrokes, features ensuring GDPR readiness.
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
• Service provider: Hotjar Ltd, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.
• Website: Hotjar.
• Privacy Policy: [Hotjar’s Privacy Policy] https://www.hotjar.com/legal/policies/privacy/.

To raise queries about the content or to understand more about the agreement, you can contact Hotjar at legal@hotjar.com.

Mixpanel Analytics and Data Management

We utilize Mixpanel, a sophisticated analytics platform, to enhance our understanding of user interactions within our online services. Below is a breakdown of how Mixpanel aligns with our data privacy commitments:

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• Data Subject Rights: As a testament to the GDPR, Mixpanel and our platform pledge to:
• Right to Access and Data Portability: Mixpanel ensures users can access and transport their personal data. Through Mixpanel, we provide means for users to request their personal data export. For further details, users can navigate to Personal Settings > Data & Privacy.
• Right to Erasure: A commitment to user data protection means allowing for permanent data deletion. Mixpanel has a Deletion API for such purposes.
• Right to Object: Users have the right to object to data collection. We ensure this right by allowing users to opt out from tracking through dedicated methods in Mixpanel. Should users wish to object, they can adjust their settings under Personal Settings > Data & Privacy.
• Data Retention Policy:
• Mixpanel abides by a structured data retention policy. Events are automatically erased post a 5-year timeframe from all projects. The inception of this retention period corresponds to the “Event Date”, typically aligning with user actions within our online service.
• User-specific data remains stored indefinitely, although we provide mechanisms for users to delete their profiles via the Engage API. However, projects that have been erased or reset through settings are subject to a soft deletion. Subsequent data within these projects is stored for a duration between 60-90 days, post which a hard deletion is executed rendering the data unrecoverable. For tailored data retention periods, users can interact with the Engage API or contact Mixpanel's support team.
• Rate Limit: To ensure system robustness and fair allocation of resources, Mixpanel implements a rate limit.

Service Provider: Mixpanel Inc.; Website: Mixpanel; Privacy Policy: Mixpanel Privacy & Security; For any data protection inquiries related to Mixpanel, users can contact their support team.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "Content") based on users' potential interests and measuring its effectiveness. 

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the users' profiles with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.

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

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• Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-based profiling, use of cookies); marketing; profiling with user-related information (creation of user profiles). Conversion measurement (measuring the effectiveness of marketing measures).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO). Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: 
• Europe: https://www.youronlinechoices.eu. 
• Canada: https://www.youradchoices.ca/choices.  
• USA: https://www.aboutads.info/choices. 
• Cross-territory: https://optout.aboutads.info.

Further guidance on processing operations, procedures and services:

• Google Ads and conversion measurement: Online marketing methods for the purpose of placing content and ads within the service provider's advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://business.safety.google/adsservices/. Data processing terms and conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
• Google Adsense with personalized ads: We use the Google Adsense service with personalized ads, with the help of which ads are displayed within our online offer and we receive remuneration for their display or other use; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://business.safety.google/adsservices/. Google Advertising Products Data Processing Terms: Information on services Data processing terms and conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
• Google Adsense with non-personalized ads: We use the Google Adsense service with non-personalized ads, with the help of which ads are displayed within our online offer and we receive remuneration for their display or other use; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis of third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.
• LinkedIn Insights Tag: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions and stores them in a profile (possible uses: measuring campaign performance, optimizing ad delivery, building custom and like audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO);
• ‍Website: https://www.linkedin.com;
• ‍Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie_policy;
• ‍Basis third country transfer: standard contractual clauses (https://legal.linkedin.com/dpa).
• ‍Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Presence in social networks (social media)

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

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

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

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements 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 also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

• Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• LinkedIn: Social network;
• ‍Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland;
• ‍Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO);
• ‍Website: https://www.linkedin.com;
• Privacy policy: https://www.linkedin.com/legal/privacy-policy;
• Order processing agreement: https://legal.linkedin.com/dpa;
• ‍Basis third country transfer: Standard Contractual Clauses (https://legal.linkedin.com/dpa).
• ‍Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plugins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing: provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

• Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer. - We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of display or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process this for the purpose of transmitting the software to the users' browsers and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• Google Fonts (sourcing from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the provider of the fonts in the USA - When visiting our online offer, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts' Cascading Style Sheets (CSS) and then with the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e., the web page where the Google font is to be displayed). IP addresses are not logged or stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must match the font that is generated for the particular browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregate usage statistics that measure the popularity of font families. These aggregate usage statistics are published on Google Fonts' Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregate report on top integrations based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
• Font Awesome (provided on own server): Display of fonts and icons; Service provider: Font Awesome icons are hosted on our server, no data is transmitted to the Font Awesome provider; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, organization and auxiliary tools

We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements. 

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. .IP addresses, time data, identification numbers, consent status).
• Data subjects: Communication partners; users (e.g., website visitors, users of online services).
• Purposes of processing: provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.

Definitions

This section provides you with an overview of the terms used in this privacy statement. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful. 
• 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 to one or more factors specific to the physical, physiological, genetic, mental, 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 that consists of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes. 
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors' behavior or interests in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering. 
• Tracking: Tracking is when the behavior of users can be traced across several online services. As a rule, behavioral and interest information relating to the online services used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests. 
• Controller: a "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. 
• Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.