Data protection

Preamble

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

The terms used are not gender-specific.

Status: March 24, 2025

Overview of Contents

Preamble
Controller
Overview of Processing
Relevant Legal Bases
Security Measures
Disclosure of Personal Data
International Data Transfers
General Information on Data Storage and Deletion
Rights of Data Subjects
Business Services
Business Processes and Procedures
Payment Methods
Provision of the Online Offering and Web Hosting
Use of Cookies
Contact and Inquiry Management
Web Analytics, Monitoring, and Optimization
Provision of an Affiliate Program
Changes and Updates
Definitions

Controller

certready.eu GmbH
Unter den Linden 26
35410 Hungen

Authorized representative: Managing Director Daniel Gal

Email address: info@certready.eu

Overview of Processing

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

Types of Data Processed

Inventory data.
Employee data.
Payment data.
Location data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication, and procedural data.
Log data.

Categories of Data Subjects

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

Purposes of Processing

Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Reach measurement.
Tracking.
Office and organizational procedures.
Conversion measurement.
Affiliate tracking.
Organizational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.
Finance and payment management.
Public relations.
Sales promotion.
Business processes and operational procedures.

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on 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 registered office. If, in individual cases, more specific legal bases are relevant, we will inform you of these in the privacy policy.

Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific regulations on the right of access, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated individual decision-making including profiling. State data protection laws of the individual federal states may also apply.

Relevant legal bases under the Swiss Federal Act on Data Protection: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (the “Swiss FADP”). Unlike the GDPR, the Swiss FADP generally does not require that a legal basis for processing personal data be specified, and processing is carried out in good faith, lawfully, and proportionately (Art. 6(1) and (2) Swiss FADP). In addition, we collect personal data only for a specific purpose that is recognizable to the data subject and process it only in a manner compatible with that purpose (Art. 6(3) Swiss FADP).

Note on the applicability of the GDPR and Swiss FADP: These privacy notices serve to provide information both under the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, please note that, due to broader geographic applicability and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP “processing” of “personal data,” “overriding interest,” and “particularly sensitive personal data,” the terms used in the GDPR “processing” of “personal data,” “legitimate interest,” and “special categories of data” are used. The legal meaning of the terms will, however, continue to be determined under the Swiss FADP where it applies.

Security Measures

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 likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security 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 access to, input into, transmission of, securing availability of, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data risks. We also take the protection of personal data into account when developing or selecting hardware, software, and procedures in accordance with the principle of data protection by design and by default.

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

Disclosure of Personal Data

In the course of processing personal data, it may happen that such data is transmitted to other entities, companies, legally independent organizational units, or persons, or disclosed to them. 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 legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of the use of services of third parties or disclosure or transmission of data to other persons, entities, or companies (which can be recognized by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is always done in accordance with legal requirements.

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

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the DPF, the Standard Contractual Clauses act as a reliable fallback. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss FADP, we disclose personal data abroad only if adequate protection of the data subjects is ensured (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we implement alternative safeguards.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of Switzerland on June 7, 2024. In addition, we have concluded Standard Data Protection Clauses with the respective providers, which have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the Standard Data Protection Clauses serve as an additional safeguard. Should changes occur within the DPF, the Standard Data Protection Clauses act as a reliable fallback. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether Standard Data Protection Clauses are in place. The list of certified companies and further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding safeguards apply, including international treaties, specific guarantees, Standard Data Protection Clauses approved by the FDPIC, or binding corporate rules recognized in advance by the FDPIC or a competent data protection authority of another country.

General Information on Data Storage and Deletion

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

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

Our privacy notices contain additional information on data retention and deletion that apply specifically to certain processing operations.

If multiple retention or deletion periods are specified for a piece of data, the longest period is always decisive.

If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the period is the effective date of termination or other ending of the legal relationship.

Data that is no longer retained for the originally intended purpose but is kept due to legal requirements or other reasons is processed by us solely for the reasons that justify its retention.

Further notes on processing operations, procedures, and services:

Retention and deletion of data: The following general periods apply to retention and archiving under German law:
- 10 years - Retention period for books and records, financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organizational documents required to understand them (§ 147(1) no. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) no. 1 in conjunction with (4) HGB).
- 8 years - Accounting records, such as invoices and cost receipts (§ 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO as well as § 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 insofar as they are relevant for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting records, and cash register strips (§ 147(1) nos. 2, 3, 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
- 3 years - Data necessary to consider potential warranty and damages claims or similar contractual claims and rights, as well as to handle related inquiries, based on past business experience and usual industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Retention and deletion of data: The following general periods apply to retention and archiving under Swiss law:
- 10 years - Retention period for books and records, financial statements, inventories, management reports, opening balance sheets, accounting records and invoices, as well as all necessary working instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years - Data necessary to consider potential damages claims or similar contractual claims and rights, as well as to handle related inquiries, based on past business experience and usual industry practices, is stored for the statutory limitation period of ten years, unless a shorter period of five years applies in certain cases (Arts. 127, 130 CO). After five years, claims for rent, lease and interest, as well as other periodic services, for delivery of food, for board and lodging, as well as from artisans’ work, retail sales of goods, medical services, professional work by lawyers, legal agents, attorneys-in-fact and notaries, and from employment relationships of employees, lapse (Art. 128 CO).

Rights of Data Subjects

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

Right to object: You have the right, on grounds relating to your particular situation, to object at any time to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw consent at any time.
Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and access to this data as well as further information and a copy of the data in accordance with legal requirements.
Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be erased without undue delay or, alternatively, to request restriction of processing of the data in accordance with legal requirements.
Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, in accordance with legal requirements, or to request its transmission to another controller.
Right to lodge a complaint with a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss FADP:

As a data subject, you have the following rights in accordance with the provisions of the Swiss FADP:

Right of access: You have the right to obtain confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to exercise your rights under this Act and to ensure transparent data processing.
Right to data delivery or transfer: You have the right to request the delivery of your personal data that you have provided to us in a commonly used electronic format.
Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
Right to object, erasure, and destruction: You have the right to object to the processing of your data and to request that personal data concerning you be erased or destroyed.

Business Services

We process data of our contractual and business partners, e.g., customers and prospects (collectively referred to as "contractual partners"), within the context of contractual and comparable legal relationships and related measures and with regard to communication with the contractual partners (or pre-contractually), for example to respond to inquiries.

We use this data to fulfill our contractual obligations. These include, in particular, obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other performance disruptions. In addition, we use the data to protect our rights and for the purpose of administrative tasks associated with these obligations and corporate organization. We also process the data on the basis of our legitimate interests both in proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information, and rights (e.g., involving 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 disclose the data of contractual partners to third parties only to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about further forms of processing, such as for marketing purposes, within this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g., in online forms, by special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data after the expiration of statutory warranty and comparable obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for archiving for legal reasons (typically ten years for tax purposes). Data disclosed to us by the contractual partner in the context of an order is deleted in accordance with the specifications and generally after the end of the order.

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or phone numbers). Contract data (e.g., subject matter of the contract, term, customer category).
Data subjects: Service recipients and clients; Prospective customers. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and operational procedures.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Provision of software and platform services: We process the data of our users, registered users, and any test users (collectively referred to as "users") in order to provide our contractual services to them and, on the basis of legitimate interests, to ensure the security of our offering and to further develop it. The required information is identified as such in the context of the order, purchase, or similar contract conclusion and includes the information needed for service provision and billing, as well as contact information to enable any necessary follow-up; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Business Processes and Procedures

Personal data of service recipients and clients—including customers, clients, or in specific cases principals, patients, or business partners, as well as other third parties—is processed in the context of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business operations in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfill contractual obligations and to design business processes efficiently. This includes processing business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal accounting and financial processes. Additionally, the data helps protect the controller’s rights and supports administrative tasks and the organization of the company.

Personal data may be shared with third parties insofar as this is necessary to fulfill the aforementioned purposes or legal obligations. After the expiration of statutory retention periods or when the purpose of processing ceases to apply, the data is deleted. This also includes data that must be stored for longer due to tax and legal documentation obligations.

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., text or image messages and posts as well as the related information such as authorship details or time of creation); Contract data (e.g., subject matter of the contract, term, customer category); Log data (e.g., log files regarding logins or the retrieval of data or access times.); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); Location data (information on the geographical position of a device or person). Employee data (information about employees and other persons in an employment relationship).
Data subjects: Service recipients and clients; Prospective customers; Communication partners; Business and contractual partners; Third parties; Users (e.g., website visitors, users of online services). Employees (e.g., salaried staff, applicants, temporary staff, and other employees).
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Business processes and operational procedures; Communication; Marketing; Sales promotion; Public relations; Finance and payment management. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legitimate interests (Art. 6(1)(f) GDPR). Legal obligation (Art. 6(1)(c) GDPR).

Further notes on processing operations, procedures, and services:

Contact management and maintenance: Procedures required for organizing, maintaining, and safeguarding contact information (e.g., setup and maintenance of a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regular review of communication history, and adjustment of contact strategies); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
General payment transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., preparing and verifying transfers, handling direct debits, checking account statements, monitoring incoming and outgoing payments, return debit management, account reconciliation, cash management); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
Accounting, accounts payable, accounts receivable: Procedures required for recording, processing, and controlling business transactions in the area of accounts payable and accounts receivable (e.g., preparing and verifying incoming and outgoing invoices, monitoring and managing open items, executing payment transactions, handling dunning processes, account reconciliation in the context of receivables and liabilities, accounts payable and accounts receivable); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
Financial accounting and taxes: Procedures required for recording, managing, and controlling financial business transactions as well as calculating, reporting, and paying taxes (e.g., account assignment and posting of business transactions, preparing quarterly and annual financial statements, executing payment transactions, handling dunning processes, account reconciliation, tax consulting, preparing and filing tax returns, handling tax matters); Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
Marketing, advertising, and sales promotion: Procedures required in the context of marketing, advertising, and sales promotion (e.g., market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of promotional materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Public relations: Procedures required in the context of public relations (PR) (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, media relations, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Payment Methods

As part 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, for this purpose, use banks, credit institutions, and 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 or credit card numbers, passwords, TANs and checksums, as well as contract-, total-, and recipient-related information. This information is required to carry out transactions. The data entered is processed and stored exclusively by the payment service providers. That is, we do not receive any account- or credit card-related information, but only information confirming the payment or indicating a negative result. The payment service providers may, under certain circumstances, transmit data to credit agencies. This transmission is intended for identity and credit checks. For this, please refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions and can be accessed within their respective websites or transaction applications. We also refer to these for further information and for asserting rights of withdrawal, access, and other data subject rights.

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Contact data (e.g., postal and email addresses or phone numbers).
Data subjects: Service recipients and clients; Business and contractual partners. Prospective customers.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Business processes and operational procedures. Office and organizational procedures.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
pathway solutions: Retrieval and processing of orders, customer data, and payment data from shop systems and other transaction platforms via interfaces. The collected data is then converted into booking information optimized for accounting procedures; Service provider: Pathway Solutions GmbH, Alstertwiete 3, 20099 Hamburg, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pathway-solutions.de/; Privacy policy: https://www.pathway-solutions.de/pages/datenschutzerklaerung; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: Switzerland - Adequacy decision (Germany).

Provision of the Online Offering and Web Hosting

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

Payment Methods

The data processed by the payment service providers include inventory data, such as name and address, bank details, such as account or credit card numbers, passwords, TANs and checksums, as well as contract-, total-, and recipient-related information. This information is required to carry out transactions. The data entered is processed and stored exclusively by the payment service providers. That is, we do not receive any account- or credit card-related information, but only information confirming the payment or indicating a negative result. The payment service providers may, under certain circumstances, transmit data to credit agencies. This transmission is intended for identity and credit checks. For this, please refer to the terms and conditions and privacy notices of the payment service providers.

Types of data processed: Inventory data (e.g., full name, residential address, contact details, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Contact data (e.g., postal and email addresses or phone numbers).
Data subjects: Service recipients and clients; Business and contractual partners. Interested parties.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Business processes and operational procedures. Office and organizational procedures.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Stripe: Payment services (technical integration of online payment methods); Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
pathway solutions: Retrieval and processing of orders, customer data, and payment data from shop systems and other transaction platforms via interfaces. The collected data is then converted into booking information optimized for accounting procedures; Service provider: Pathway Solutions GmbH, Alstertwiete 3, 20099 Hamburg, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pathway-solutions.de/; Privacy policy: https://www.pathway-solutions.de/pages/datenschutzerklaerung. Data Processing Agreement: Provided by the service provider.

Provision of the Online Offering and Web Hosting

Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); Log data (e.g., log files regarding logins or retrieval of data or access times). Content data (e.g., text or image messages and posts as well as related information, such as authorship details or time of creation).
Data subjects: Users (e.g., website visitors, users of online services). Business and contractual partners.
Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures. Office and organizational procedures.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

bunny.net: Content Delivery Network (CDN) service that helps deliver content of an online offering, especially large media files such as graphics or program scripts, faster and more securely using regionally distributed servers connected via the internet. Also used to manage rights to transmitted content and to help prevent unauthorized use of provided materials; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Data Processing Agreement: Provided by the service provider; Service provider: BUNNYWAY d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia; Website: https://bunny.net. Privacy policy: https://bunny.net/privacy/.
Provision of online offering on rented storage: For the provision of our online offering, we use storage space, computing capacity, and software that we rent from or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." Server log files can include the address and name of the retrieved web pages and files, date and time of retrieval, transferred data volumes, messages about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and also to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidence purposes is exempt from deletion until the respective incident is finally clarified.
Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage and/or computing capacity); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
United Domains: Services in the field of providing information technology infrastructure and related services (e.g., storage and/or computing capacity); Service provider: united-domains AG, Gautinger Straße 10, 82319 Starnberg, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.united-domains.de; Privacy policy: https://www.united-domains.de/unternehmen/datenschutz/. Data Processing Agreement: https://www.united-domains.de/help/faq-article/wie-erhalte-ich-den-auftragsverarbeitungs-vertrag-avv-nach-dsgvo/.
Webflow: Creation, management, and hosting of websites, online forms, and other web elements; Service provider: Webflow, Inc., 398 11th St., Floor 2, 94103 San Francisco, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://webflow.com; Privacy policy: https://webflow.com/legal/eu-privacy-policy; Data Processing Agreement: https://webflow.com/legal/dpa. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://webflow.typeform.com/to/nM8vLH), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses (https://webflow.typeform.com/to/nM8vLH).

Use of Cookies

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies can also be used for various purposes, such as ensuring functionality, security, and convenience of online offerings, as well as analyzing visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information about the scope of usage and which cookies are used.

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

Storage duration: With regard to 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 their device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after closing the device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, user data collected via cookies can be used for reach measurement. If we do not provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General notes on withdrawal and objection (opt-out): Users can withdraw their consent at any time and can also lodge an objection to processing in accordance with legal requirements, including via the privacy settings of their browser.

Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Data subjects: Users (e.g., website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further notes on processing operations, procedures, and services:

Processing of cookie data based on consent: We use a consent management solution in which users’ consent to the use of cookies or to the procedures and providers mentioned within the consent management solution is obtained. This procedure serves to collect, record, manage, and withdraw consents, particularly regarding the use of cookies and comparable technologies used to store, read, and process information on users’ devices. As part of this procedure, users’ consent for the use of cookies and the related processing of information, including the specific processing and providers mentioned in the consent management procedure, is obtained. Users also have the option to manage and withdraw their consents. Consent statements are stored to avoid repeated prompts and to be able to prove consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to assign consent to a specific user or their device. Unless specific information is provided about the providers of consent management services, the following general notes apply: The storage duration of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of the consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used; Legal bases: Consent (Art. 6(1)(a) GDPR).

Contact and Inquiry Management

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

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., text or image messages and posts, as well as related information such as authorship details or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Data subjects: Communication partners.
Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further notes on processing operations, procedures, and services:

Contact form: When contacting us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to respond to and handle the respective request. This generally includes information such as name, contact details, and, where applicable, additional information provided to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as "reach measurement") serves to evaluate the visitor flows of 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 recognize, for example, at what time our online offering or its functions or content are most frequently used, or invite reuse. It also enables us to identify 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 may be created for these purposes, i.e., data aggregated into a usage process, and information may be stored and then read in a browser or on a device. The information collected includes, in particular, visited websites 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 to us or to 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 procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored as part of web analytics, A/B testing, and optimization, but pseudonyms. 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 purposes of the respective procedures.

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

Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
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).
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion." Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can 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 notes on processing operations, procedures, and services:

Google Tag Manager: We use Google Tag Manager, software from Google that allows us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that serve to capture and analyze visitor activities. This technology helps us improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles, or perform independent analyses. Its function is limited to simplifying and making the integration and management of tools and services we use on our website more efficient. Nevertheless, when using Google Tag Manager, users' IP addresses are transmitted to Google, which is technically required to implement the services we use. Cookies may also be set. This data processing only occurs when services are integrated via Tag Manager. For more detailed information about these services and their data processing, please refer to the relevant sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EU/EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland - Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms).

Provision of an Affiliate Program

We offer an affiliate program, i.e., commissions or other benefits (collectively referred to as "commission") for users (referred to as "affiliates") who refer to our offers and services. The referral is made using a link assigned to the respective affiliate or other methods (e.g., discount codes) that allow us to recognize that the use of our services was based on the referral (collectively referred to as "affiliate links").

To track whether users used our services due to affiliate links deployed by affiliates, it is necessary for us to know that users followed an affiliate link. The assignment of affiliate links to the respective transactions or other use of our services serves solely the purpose of commission billing and is removed as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, affiliate links can be supplemented by certain values that are part of the link or can be stored otherwise, e.g., in a cookie. The values may include, in particular, the originating website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

Notes on legal bases: The processing of our partners’ data is carried out for the provision of our (pre-)contractual services. Users’ data is processed on the basis of their consent.

Types of data processed: Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Log data (e.g., log files regarding logins or retrieval of data or access times). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Data subjects: Users (e.g., website visitors, users of online services). Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Affiliate tracking; Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest-/behavior-based profiling, use of cookies); Conversion measurement (measurement of the effectiveness of marketing measures). Marketing.
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures, and services:

Rewardful: Management of affiliate and referral programs, tracking referrals, calculating commissions, integration with payment providers for automated payouts, analysis of program performance, and adjustment of program settings; Service provider: Rewardful Inc., Suite 3810 Bankers Hall West, 888 3rd Street SW, T2P 5C5 Calgary, Canada; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.rewardful.com/; Privacy policy: https://www.rewardful.com/privacy. Data Processing Agreement: https://trust.rewardful.com/.

Changes and Updates

Please review the content of our privacy policy regularly. We will adapt the privacy policy as soon as changes in our data processing make this necessary. We will inform you if 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 addresses may change over time and verify the information before contacting them.

Definitions

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

Affiliate tracking: In affiliate tracking, links that refer users from linking websites to websites with product or other offers are recorded. The operators of the linking websites may receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., purchase goods or use services). For this purpose, providers need to be able to track whether users who are interested in certain offers subsequently take advantage of them due to the affiliate links. Therefore, for affiliate links to function, they must be supplemented with certain values that become part of the link or are stored otherwise, e.g., in a cookie. The values include, in particular, the originating website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values, such as, e.g., ad ID, partner ID, and categorizations
Employees: Employees are persons in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It includes the employer’s obligation to pay remuneration while the employee performs their work. The employment relationship comprises various phases, including initiation, when the employment contract is concluded; performance, when the employee performs their work; and termination, when the employment relationship ends, whether through dismissal, termination agreement, or otherwise. Employee data includes all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance evaluations.
Inventory data: Inventory data includes essential information necessary for identifying and managing contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact details (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique assignment and communication.
Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates
Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, postal addresses, and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
Conversion measurement: Conversion measurement (also called "visit action evaluation") is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, this allows us to understand whether the ads we placed on other websites were successful.
Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details such as file size, creation date, the author of a document, and change histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission routes. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and verify operations.
Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and which paths they navigate through an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or 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 form of automated processing of personal data that consists of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged in a system or network. These data typically contain information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system issues, for security monitoring, or to create performance reports.
Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and may include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can recognize, for example, at what times users visit their websites and which content they are interested in. This enables them to better adapt the content of the websites to the needs of their visitors. For the purpose of reach measurement, 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.
Location data: Location data is generated when a mobile device (or another device capable of determining location) connects to a cell tower, Wi-Fi, or similar technical means and functions of location determination. Location data indicates the geographically determinable position on earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
Tracking: "Tracking" refers to when users’ behavior can be traced across multiple online offerings. As a rule, behavior and interest information related to the used online offerings is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
Controller: "Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether collecting, evaluating, storing, transmitting, or deleting.
Contract data: Contract data is specific information related to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options, and special terms or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction data, verification numbers, and billing information. Payment data may also include information about payment status, chargebacks, authorizations, and fees.