Privacy Policy
Preamble
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also
abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all
processing of personal data carried out by us, both in the context of providing our services and in particular on
our websites, in mobile applications and within external online presences, such as our social media profiles
(hereinafter collectively referred to as "online services").
The terms used are not gender-specific.
Preamble
With the following privacy policy we would like to inform you about the types of personal data (hereinafter also
referred to as "data") we process, for which purposes and to what extent in the context of providing our
application.
The terms used are not gender-specific.
Last Update: 26. November 2025
Table of contents
Controller
Prokisch & Thumbs Software GbR
Schlehenweg 1
92331 Parsberg
Authorised Representatives: Leonard Prokisch, Jonas Thumbs
E-mail address: skillsplash.app@gmail.com
Contact information of the Data Protection Officer
jonas.thumbs@gmail.com
Overview of processing operations
The following table summarises the types of data processed, the purposes for which they are processed and the
concerned data subjects.
Categories of Processed Data
- Inventory data.
- Payment Data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Log data.
Categories of Data Subjects
- Service recipients and clients.
- Employees.
- Prospective customers.
- Communication partner.
- Users.
- Business and contractual partners.
- Education and course participants.
- Third parties.
- Customers.
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Web Analytics.
- Targeting.
- Office and organisational procedures.
- Affiliate Tracking.
- Organisational and Administrative Procedures.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Authentication processes.
- Provision of our online services and usability.
- Information technology infrastructure.
- Financial and Payment Management.
- Public relations.
- Sales promotion.
- Business processes and management procedures.
- Artificial Intelligence (AI).
Relevant legal bases
Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal
basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions
of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in
addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data
protection declaration.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his
or her personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a
contract to which the data subject is party or in order to take steps at the request of the data subject prior
to entering into a contract.
- Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for
compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection
of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights,
and freedoms of the data subject, which require the protection of personal data, do not prevail.
National data protection regulations in Germany: In addition to the data protection regulations of
the GDPR, national regulations apply to data protection in Germany. This includes in particular the Law on
Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular,
the BDSG contains special provisions on the right to access, the right to erase, 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. Furthermore, data protection laws of the individual federal states
may apply.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland,
we process your data based on the Federal Act on Data Protection (referred to as "Swiss DPA"). Unlike the GDPR, for
instance, the Swiss DPA does not generally require that a legal basis for processing personal data be stated and
that the processing of personal data is conducted in good faith, lawfully and proportionately (Art. 6 para. 1 and 2
of the Swiss DPA). Furthermore, we only collect personal data for a specific purpose recognizable to the data
subject and process it only in a manner compatible with this purpose (Art. 6 para. 3 of the Swiss DPA).
Reference to the applicability of the GDPR and the Swiss DPA: These privacy policy serves both to
provide information pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection
Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and
comprehensibility, the terms used in the GDPR are applied. In particular, instead of the terms used in the Swiss
FADP such as "processing" of "personal data", "predominant interest", and "particularly sensitive personal data",
the terms used in the GDPR, namely "processing" of "personal data", as well as "legitimate interest" and "special
categories of data" are used. However, the legal meaning of these terms will continue to be determined according to
the Swiss FADP within its scope of application.
Security Precautions
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into
account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing
as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to
ensure a level of security appropriate to the risk.
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 access to, input, transmission, securing and
separation of the data. In addition, we have established procedures to ensure that data subjects' rights are
respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take
the protection of personal data into account as early as the development or selection of hardware, software and
service providers, in accordance with the principle of privacy by design and privacy by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted
via our online services from unauthorized access, we employ 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 that is transferred between the website or app and the user's browser (or
between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure
version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is
secured with 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 securely and encryptedly transmitted.
Transmission of Personal Data
In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other
entities, companies, legally independent organizational units, or individuals. Recipients of this data may include
service providers tasked with IT duties or providers of services and content that are integrated into a website. In
such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve
to protect your data with the recipients of 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 if this occurs in the context of using third-party services or the disclosure
or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal
address of the respective provider or when explicitly mentioned in the privacy policy regarding 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 has been recognized as a
secure legal framework by the EU Commission's adequacy decision of July 10, 2023. Additionally, we have concluded
Standard Contractual Clauses with the respective providers, which 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 serves as the primary level of protection,
while the Standard Contractual Clauses act as an additional security measure. Should any changes occur within the
DPF framework, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your
data remains adequately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and if Standard
Contractual Clauses are in place. The list of certified companies and further information about the DPF can be found
on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, appropriate safeguards apply, particularly 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 EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data
protection notices.
Disclosure of Personal Data Abroad: In accordance with the Swiss Data Protection Act (Swiss DPA), we only disclose
personal data abroad when an appropriate level of protection for the affected persons is ensured (Art. 16 Swiss
DPA). If the Federal Council has not determined an adequate level of protection (list of states: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html),
we implement alternative security measures.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a
secure legal framework by Switzerland's adequacy decision of June 7, 2024. Additionally, 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 serves as the primary level of protection,
while the Standard Data Protection Clauses act as an additional security measure. Should any changes occur within
the DPF framework, the Standard Data Protection Clauses will serve as a reliable fallback option. This ensures that
your data remains adequately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and if Standard Data
Protection Clauses are in place. The list of certified companies and further information about the DPF can be found
on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, appropriate safeguards apply, including international agreements,
specific guarantees, FDPIC-approved Standard Data Protection Clauses, or internal company data protection
regulations previously recognized by the FDPIC or a competent data protection authority of another country.
Under Art. 16 of the Swiss DPA, exceptions can be made for the disclosure of data abroad if certain conditions are
met, including the consent of the affected person, contract execution, public interest, protection of life or
physical integrity, publicly made data, or data from a legally provided register. Such disclosures always comply
with the legal requirements.
We will inform you which of our service providers are certified under the Data Privacy Framework as part of our
privacy notices.
General Information on Data Retention and Deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are
revoked or no further legal bases for processing exist. This applies to cases where the original purpose of
processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory
obligations or special interests require a longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal
prosecution or protection of the rights of other natural or legal persons, must be archived accordingly.
Our privacy notices contain additional information on the retention and deletion of data specifically applicable to
certain processing processes.
In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always
prevails.
Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are
processed exclusively for the reasons justifying their retention.
Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to
German law:
- 10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements,
inventories, management reports, opening balance sheet as well as the necessary work instructions and other
organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General
Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in
conjunction with Paragraph 4 of the German Commercial Code (HGB)).
- 8 years - Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4
and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in
conjunction with Paragraph 4 of the German Commercial Code (HGB))
- 6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or
business letters, and other documents to the extent that they are significant for taxation purposes, for
example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll
accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section
147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257
Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
- 3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and
rights, as well as to process related inquiries, based on previous business experiences and common industry
practices, will be stored for the duration of the regular statutory limitation period of three years. This
period begins at the end of the year in which the relevant contractual transaction took place or the contractual
relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).
Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports,
opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other
organizational documents (Article 958f of the Swiss Code of Obligations (OR)).
- 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as
well as for the processing of related inquiries based on previous business experiences and usual industry
practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five
years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and
interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for
innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services
by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire
after five years (Article 128 OR).
Rights of Data Subjects
Rights of the Data Subjects under the GDPR: As data subject, you are entitled to various rights under the GDPR, which
arise in particular from Articles 15 to 21 of the GDPR:
- Right to Object: You have the right, on grounds arising from your particular situation, to object at any
time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR,
including profiling based on those provisions. Where personal data are processed for direct marketing
purposes, you have the right to object at any time to the processing of the personal data concerning you for
the purpose of such marketing, which includes profiling to the extent that it is related to such direct
marketing.
- Right of withdrawal for consents: You have the right to revoke consents at any time.
- Right of access: You have the right to request confirmation as to whether the data in question
will be processed and to be informed of this data and to receive further information and a copy of the data in
accordance with the provisions of the law.
- Right to rectification: You have the right, in accordance with the law, to request the
completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing: In accordance with the statutory
provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to
demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive data concerning you which you have
provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or
to request its transmission to another controller.
- Complaint to the supervisory authority: In accordance with the law 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 where you habitually reside,
the supervisory authority of your place of work or the place of the alleged infringement, if you consider that
the processing of personal data concerning you infringes the GDPR.
Rights of the data subjects under the Swiss DPA:
As the data subject, you have the following rights in accordance with the provisions of the Swiss DPA:
- Right to information: You have the right to request confirmation as to whether personal data
concerning you are being processed, and to receive the information necessary for you to assert your rights under
the Swiss DPA and to ensure transparent data processing.
- Right to data release or transfer: You have the right to request the release of your personal
data, which you have provided to us, in a common electronic format, as well as its transfer to another data
controller, provided this does not require disproportionate effort.
- Right to rectification: You have the right to request the rectification of inaccurate personal
data concerning you.
- Right to object, deletion, and destruction: You have the right to object to the processing of
your data, as well as to request that personal data concerning you be deleted or destroyed.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively
referred to as "contractual partners") within the context of contractual and comparable legal relationships as well
as associated actions and communication with the contractual partners or pre-contractually, 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 economical 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 privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context
of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the
like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4
years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory
retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance
sheets, annual financial statements, the instructions required to understand these documents and other
organizational documents and accounting records is ten years and for received commercial and business letters and
reproductions of sent commercial and business letters six years. The period begins at 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 record was made or the other documents were created.
- Processed data types: Inventory data (For example, the 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. contract object, duration, customer
category).
- Data subjects: Service recipients and clients; Prospective customers; Business and contractual
partners. Education and course participants.
- Purposes of processing: Provision of contractual services and fulfillment of contractual
obligations; Communication; Office and organisational procedures; Organisational and Administrative Procedures.
Business processes and management procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR);
Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Education and Training Services: We process the data of the participants of our education and
training programmes (uniformly referred to as " students") in order to provide them with our educational and
training services. The data processed, the type, scope and purpose of the processing and the necessity of its
processing are determined by the underlying contractual and educational relationship. The processing also
includes the performance evaluation and evaluation of our services and the teachers and instructors.
As
part of our activities, we may also process special categories of data, in particular information on the health
of persons undergoing training or further training and data revealing ethnic origin, political opinions,
religious or philosophical convictions. To this end, we obtain, if necessary, the express consent of the
students to be trained and further educated and process the special categories of data otherwise only if it is
necessary for the provision of training services, for purposes of health care, social protection or protection
of vital interests of the students to be trained and further educated; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Online Courses and Online Training: We process the data of participants in our online courses
and training sessions (collectively referred to as "participants") in order to be able to provide them with our
course and training services. The data processed, the type, scope, purpose, and necessity of their processing
are determined by the underlying contractual relationship. The data generally includes information on the
courses and services utilized, as well as personal preferences and results of the participants, insofar as they
are part of our service offering. Processing forms also include performance evaluation and the evaluation of our
services as well as those of the course and training instructors. Additionally, depending on the equipment and
structure of the respective courses or learning content, further processing operations may be implemented, such
as attendance tracking for documenting participation, progress monitoring for measuring and analyzing learning
progress by collecting exam and test results, and analyzing interactions on learning platforms, such as forum
posts and assignment submissions; Legal Basis: Performance of a contract and
prior requests (Article 6 (1) (b) GDPR).
- Software and Platform Services: We process the data of our users, registered and any test users
(hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the
basis of legitimate interests to ensure the security of our offer and to develop it further. The required
details are identified as such within the context of the conclusion of the agreement, order or comparable
contract and include the details required for the provision of services and invoicing as well as contact
information in order to be able to hold any further consultations; Legal Basis:
Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Business processes and operations
Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates,
patients, or business partners as well as other third parties - are processed within the framework of contractual
and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This
data processing supports and facilitates business processes in areas such as customer management, sales, payment
transactions, accounting, and project management.
The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the
execution of business transactions, the management of customer relationships, the optimisation of sales strategies,
and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the
rights of the controller and promotes administrative tasks as well as the organisation of the company.
Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal
obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will
be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to
provide evidence.
- Processed data types: Inventory data (For example, the 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. textual or pictorial messages and
contributions, as well as information pertaining to them, such as details of authorship or the time of
creation.); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and
duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used,
interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps,
identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or
access times.).
- Data subjects: Service recipients and clients; Prospective customers; Communication partner
(Recipients of e-mails, letters, etc.); Business and contractual partners; Customers; Third parties; Users (e.g.
website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and
other personnel.).
- Purposes of processing: Provision of contractual services and fulfillment of contractual
obligations; Office and organisational procedures; Business processes and management procedures; Security
measures; Provision of our online services and usability; Communication; Marketing; Sales promotion; Public
relations; Financial and Payment Management. Information technology infrastructure (Operation and provision of
information systems and technical devices, such as computers, servers, etc.)).
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR);
Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).
Further information on processing methods, procedures and services used:
- Contact management and contact maintenance: Processes required in the context of organizing,
maintaining, and securing contact information (e.g., setting up and maintaining a central contact database,
regular updates of contact information, monitoring data integrity, implementing data protection measures,
ensuring access controls, conducting backups and restorations of contact data, training employees in effective
use of contact management software, regular review of communication history and adjustment of contact
strategies); Legal Basis: Performance of a contract and prior requests (Article
6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Customer Account: Customers can create an account within our online offer (e.g. customer or
user account, "customer account" for short). If the registration of a customer account is required, customers
will be informed of this as well as of the details required for registration. The customer accounts are not
public and cannot be indexed by search engines. In the course of registration and subsequent registration and
use of the customer account, we store the IP addresses of the contractual partners along with the access times,
in order to be able to prove the registration and prevent any misuse of the customer account. If the customer
account has been terminated, the customer account data will be deleted after the termination date, unless it is
retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g.
internal storage of customer data, order transactions or invoices). It is the customers' responsibility to back
up their data when terminating the customer Account; Legal Basis: Performance of
a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f)
GDPR).
- General Payment Transactions: Procedures required for carrying out payment transactions,
monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers,
processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing
payments, management of chargebacks, account reconciliation, cash management); Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for the collection,
processing, and control of business transactions in the area of accounts payable and receivable accounting
(e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding
items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope
of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f)
GDPR).
- Financial Accounting and Taxes: Procedures required for the collection, management, and control
of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g.,
accounting and posting of business transactions, preparation of quarterly and annual financial statements,
execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting,
preparation and submission of tax returns, management of tax affairs); Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a
legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Marketing, advertising, and sales promotion: Processes required in the context of marketing,
advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing
strategies, planning and execution of advertising campaigns, design and production of advertising materials,
online marketing including SEO and social media campaigns, event marketing and trade show participation,
customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing
activities, budget management and cost control); Legal Basis: Legitimate
Interests (Article 6 (1) (f) GDPR).
- Public Relations: Processes required in the context of public relations and public relations
activities (e.g., development and implementation of communication strategies, planning and execution of PR
campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis
of media response, organisation of press conferences and public events, crisis communication, creation of
content for social media and corporate websites, management of corporate branding); Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Payment Procedure
Within the framework 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 for this purpose in addition to banks and credit institutions (collectively referred to as "payment
service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with
the state of the art, ensuring that the data entered is protected from unauthorized access during transmission.
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 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 data may be transmitted by the payment service providers to credit agencies. The
purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and
data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the
payment transactions and can be accessed within the respective websites or transaction applications. We also refer
to these for further information and the assertion of revocation, information and other data subject rights.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contract data
(e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click
paths, intensity and frequency of use, types of devices and operating systems used, interactions with content
and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers,
involved parties). 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 management procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Apple Pay: Payment services provider; Service provider: Apple Inc., Infinite
Loop, Cupertino, CA 95014, USA; Legal Basis: Performance of a contract and prior
requests (Article 6 (1) (b) GDPR); Website: https://www.apple.com/apple-pay/.
Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.
- Google Pay: Payment services provider; Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis:
Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Website: https://pay.google.com/intl/en_uk/about/. Privacy Policy: https://policies.google.com/privacy.
- PayPal: Payment-Service-Provider (technical integration of online-payment-methods) (e.g.
PayPal, PayPal Plus, Braintree, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie,
S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal Basis: Performance of a
contract and prior requests (Article 6 (1) (b) GDPR); Website: https://www.paypal.com. Privacy Policy:
https://www.paypal.com/de/legalhub/paypal/privacy-full.
Provision of online services and web hosting
We process user data in order to be able to provide them with our online services. For this purpose, we process the
IP address of the user, which is necessary to transmit the content and functions of our online services to the
user's browser or terminal device.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features);
Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
Log data (e.g. log files concerning logins or data retrieval or access times.).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and usability; Information technology
infrastructure (Operation and provision of information systems and technical devices, such as computers,
servers, etc.)). Security measures.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a)
GDPR).
Further information on processing methods, procedures and services used:
- Provision of online offer on rented hosting space: For the provision of our online services, we
use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server
provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR).
- Collection of Access Data and Log Files: Access to our online service is logged in the form of
so-called "server log files". Server log files may include the address and name of the accessed web pages and
files, date and time of access, transferred data volumes, notification of successful retrieval, browser type
along with version, the user's operating system, referrer URL (the previously visited page), and typically IP
addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent
server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load
management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR). Retention period: Log file information is stored for a maximum period of 30
days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are
excluded from deletion until the respective incident has been finally clarified.
- Firebase Crashlytics: Collection and analysis of crash reports, real-time crash reports for
quick error resolution, provision of detailed insights into the causes of app crashes, grouping similar crashes
for easier management and identification of critical issues, integration with other developer tools to optimise
workflows. In the event of a crash, anonymous information is transmitted to Google's servers in the USA (app
state at the time of the crash, installation UUID, crash trace, manufacturer and operating system of the device,
last log messages). This information does not contain personal data. Crash reports are only sent with your
explicit consent. When using iOS apps, you can give consent in the app settings or after a crash. For Android
apps, there is an option during mobile device setup to generally consent to sending crash notifications to
Google and app developers; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s
Quay, Dublin 2, Ireland; Legal Basis: Consent (Article 6 (1) (a) GDPR),
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://firebase.google.com/products/crashlytics; Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
Use of Cookies
The term "cookies" refers to functions that store information on users' devices and read it from them. Cookies can
also be used for different purposes, such as ensuring the functionality, security, and convenience of online
services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. If 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, saving settings and ensuring the functionality and security of our online services. Consent
can be withdrawn at any time. We clearly inform users about the scope of the consent and which cookies are used.
Information on legal data protection bases: Whether we process personal data using cookies depends
on users' consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate
interests, as outlined in this section and in the context of the respective services and procedures.
Storage duration: The following types of cookies are distinguished based on their storage duration:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a
user leaves an online service and closes their device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the device is closed. For
example, the login status can be saved, and preferred content can be displayed directly when the user revisits a
website. Additionally, the user data collected with cookies may be used for audience measurement. Unless we
provide explicit information to users about the type and storage duration of cookies (e.g., when obtaining
consent), users should assume that these are permanent and may have a storage duration of up to two years.
General information on withdrawal and objection (opt-out): Users can withdraw their consent at any
time and also object to the processing according to legal regulations, including through the privacy settings of
their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, timestamps,
identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Consent (Article 6 (1) (a)
GDPR).
Further information on processing methods, procedures and services used:
- Processing Cookie Data on the Basis of Consent: We implement a consent management solution that
obtains users' consent for the use of cookies or for the processes and providers mentioned within the consent
management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly
regarding the use of cookies and similar technologies employed to store, read from, and process information on
users' devices. As part of this procedure, user consents are obtained for the use of cookies and the associated
processing of information, including specific processing and providers named in the consent management process.
Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid
repeated queries and to provide proof of consent according to legal requirements. The storage is carried out
server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to
associate the consent with a specific user or their device.If no specific details about the providers of consent
management services are provided, the following general notes apply: The duration of consent storage is up to
two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on
the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information
about the browser, system, and device used; Legal Basis: Consent (Article 6 (1)
(a) GDPR).
Processing of Data within the Application (App)
We process the data of the users of our application to the extent necessary to provide the users with the application
and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in
compliance with the statutory provisions if communication is necessary for the purposes of administration or use of
the application. In addition, we refer to the data protection information in this privacy policy with regard to the
processing of user data.
Legal basis: The processing of data necessary for the provision of the functionalities of the
application serves to fulfil contractual obligations. This also applies if the provision of the functions requires
user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision
of the functionalities of the application, but serves the security of the application or our business interests
(e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on
the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of
their data, the data covered by the consent is processed on the basis of the consent.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features);
Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties);
Payment Data (e.g. bank details, invoices, payment history). Contract data (e.g. contract object, duration,
customer category).
- 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. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Commercial use: We process the data of the users of our application, registered and any test
users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and
on the basis of legitimate interests to ensure the security of our application and to develop it further. The
required details are identified as such within the scope of the conclusion of a contract for the use of the
application, the conclusion of an order, an order or a comparable contract and may include the details required
for the provision of services and any invoicing as well as contact information in order to be able to hold any
consultations; Legal Basis: Performance of a contract and prior requests
(Article 6 (1) (b) GDPR).
- Storage of the universally unique identifier (UUID): The application stores a so-called
Universally Unique Identifier (UUID) for the purpose of analysing the use and functionality of the application
and storing the user's settings. This identifier is generated when the application is installed (but is not
connected to the device, so no device ID in this sense), remains stored between the start of the application and
its updates and is deleted when users remove the application from their device.
- Storage of an own unique identifier: In order to provide the application and ensure its
functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no clear data such
as names are used) that is assigned to a device and/or the installation of the application installed on it. This
identifier is generated during the installation of the application, remains stored between the start of the
application and its updates and is deleted when users remove the application from the device.
- Device authorizations for access to functions and data: The use of certain functions of our
application may require access to the camera and the stored recordings of the users. By default, these
authorizations must be granted by the user and can be revoked at any time in the settings of the respective
devices. The exact procedure for controlling app permissions may depend on the user's device and software. Users
can contact us if they require further explanation. We would like to point out that the refusal or revocation of
the respective authorizations can affect the functionality of our application.
Purchase of applications via Appstores
The purchase of our apps is done via special online platforms operated by other service providers (so-called
"appstores"). In this context, the data protection notices of the respective appstores apply in addition to our data
protection notices. This applies in particular with regard to the methods used on the platforms for webanalytics and
for interest-related marketing as well as possible costs.
- Processed data types: Inventory data (For example, the 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. contract object, duration, customer
category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types
of devices and operating systems used, interactions with content and features). Meta, communication and process
data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Service recipients and clients. Users (e.g. website visitors, users of online
services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual
obligations. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
Registration, Login and User Account
Users can create a user account. Within the scope of registration, the required mandatory information is communicated
to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of
obligations. The processed data includes in particular the login information (name, password and an e-mail address).
Within the scope of using 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
the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties
unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail of information relevant to their user account, such as technical changes.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content
data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as
details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths,
intensity and frequency of use, types of devices and operating systems used, interactions with content and
features). Log data (e.g. log files concerning logins or data retrieval or access times.).
- 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; Organisational and Administrative Procedures. Provision of our online services
and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion". Deletion after termination.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Registration with pseudonyms: Users may use pseudonyms as user names instead of real names;
Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- Users' profiles are public: Users' profiles are publicly visible and accessible.
- Deletion of data after termination: If users have terminated their user account, their data
relating to the user account will be deleted, subject to any legal permission, obligation or consent of the
users; Legal Basis: Performance of a contract and prior requests (Article 6 (1)
(b) GDPR).
- No obligation to retain data: It is the responsibility of the users to secure their data before
the end of the contract in the event of termination. We are entitled to irretrievably delete all user data
stored during the term of the contract; Legal Basis: Performance of a contract
and prior requests (Article 6 (1) (b) GDPR).
- Publishing Courses: When you publish courses, personal data (e.g., your username) may be
associated with the published content. This data is visible to other users as long as the course remains public.
If you delete the course, this information will be removed from the platform. However, copies that were
previously downloaded or cached by other users may still exist and cannot be fully revoked retroactively. Your
public profile may also be linked to your published courses and visible to other users.
Community Functions
The community functions provided by us allow users to engage in conversations and other forms of interaction 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.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.). Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features).
- 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. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- User contributions are public: The posts and content created by users are publicly visible and
accessible; Legal Basis: Performance of a contract and prior requests (Article 6
(1) (b) GDPR).
- Storage of data for security purposes: The posts and other entries of the users are processed
for the purposes of the community and conversation functions and, subject to legal obligations or legal
permission, are not disclosed to third parties. An obligation to disclosure may arise in particular in the case
of unlawful posts for the purposes of legal prosecution. We would like to point out that, in addition to the
content of the posts, their time and the IP address of the user are also stored. This is done in order to be
able to take appropriate measures to protect other users and the community; Legal
Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
- Right to delete content and information: The deletion of posts, content or information provided
by users is permissible to the extent necessary after proper consideration if there are concrete indications
that they could represent a violation of legal regulations, our provisions or the rights of third parties; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
- Protection of own data: Users decide for themselves what data they disclose about themselves
within our online services. For example, when users provide personal information or participate in
conversations. We ask users to protect their data and to publish personal data only with caution and only to the
extent necessary. In particular, we ask users to note that they must protect their login credentials in
particular and use secure passwords (preferably long and random combinations of characters); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b)
GDPR).
Single Sign-on Authentication
Single Sign-On" or "Single Sign-On Authentication or Logon" are procedures that allow users to log in to our online
services using a user account with a provider of Single Sign-On services (e.g. a social network). 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 logged in with the Single
Sign-On provider and confirm the Single Sign-On login via the button.
Authentication takes place directly with the respective single sign-on provider. Within the scope of such
authentication, we receive a user ID with the information that the user is logged in with the respective single
sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called "user handle").
Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as
part of authentication and also which data users have released in the privacy or other settings of the user account
with the single sign-on provider. Depending on the single sign-on provider and the user's choice, there can be
different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as
part of the single sign-on procedure is neither visible to us nor is it stored by us.
Users are requested to note that their data stored with us can be automatically compared with their user account with
the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of
users change, users must change these manually in their user account with us.
We can use single sign-on authentication, provided that it has been agreed with users in the context of
pre-fulfillment or fulfilment of the contract, in the context of consent processing and otherwise use it on the
basis of our legitimate interests and the interests of users in an effective and secure authentication system.
Should users decide to no longer want 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.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Usage data
(e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and
operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP
addresses, timestamps, identification numbers, involved parties).
- 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; Authentication processes. Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion". Deletion after termination.
- Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Apple Single-Sign-On: Authentication services for user logins, provision of single sign-on
functionalities, management of identity information and application integrations; Service
provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.apple.com. Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.
- Google Single-Sign-On: Authentication services for user logins, provision of single sign-on
functionalities, management of identity information and application integrations; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Website: https://www.google.com;
Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers:
EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF). Opt-Out:
Settings for the Display of Advertisements: https://myadcenter.google.com/personalizationoff.
- Microsoft Single-Sign-On: Authentication services for user logins, provision of single sign-on
functionalities, management of identity information and application integrations; Service
provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park,
Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests
(Article 6 (1) (f) GDPR); Website: https://www.microsoft.com/en-gb/security/business/identity-access/azure-active-directory-single-sign-on;
Privacy Policy: https://privacy.microsoft.com/en-gb/privacystatement; Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
Further Information: https://www.microsoft.com/en-gb/trust-center.
- Firebase Authentication: Authentication of users, management of user accounts, password reset,
email/password login, login with third-party providers such as Google or Facebook, multi-factor authentication,
session management and monitoring of suspicious activities; Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate
Interests (Article 6 (1) (f) GDPR); Website: https://firebase.google.com/products/auth; Privacy Policy: https://policies.google.com/privacy.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data
Privacy Framework (DPF).
Contact and Inquiry Management
When contacting us (e.g. via 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.
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content
data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as
details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths,
intensity and frequency of use, types of devices and operating systems used, interactions with content and
features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved
parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
- Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback
(e.g. collecting feedback via online form). Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract
and prior requests (Article 6 (1) (b) GDPR).
Further information on processing methods, procedures and services used:
- Contact form: Upon contacting us via our contact form, email, or other means of communication,
we process the personal data transmitted to us for the purpose of responding to and handling the respective
matter. This typically includes details such as name, contact information, and possibly additional information
provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose
of contact and communication; Legal Basis: Performance of a contract and prior
requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Artificial Intelligence (AI)
We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our
interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI
Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation,
capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or
decisions that can influence physical or virtual environments.
Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for
artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness,
transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We
ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of
the data subjects or a statutory permission.
When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In
accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also
observe our duties when using or operating the acquired AI services. The processing of personal data by us and the
AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis
on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.
To protect processed data, we implement appropriate and robust technical as well as organisational measures. These
ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of
AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Processed data types: Content data (e.g. textual or pictorial messages and contributions, as
well as information pertaining to them, such as details of authorship or the time of creation.). Usage data
(e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and
operating systems used, interactions with content and features).
- Data subjects: Users (e.g. website visitors, users of online services). Third parties.
- Purposes of processing: Artificial Intelligence (AI).
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- ChatGPT: AI-based service designed to understand and generate natural language and related
input and data, analyze information, and make predictions ("AI", meaning "Artificial Intelligence" shall be
construed in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd,
117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://openai.com/chatgpt/overview/;
Privacy Policy: https://openai.com/policies/privacy-policy/. Opt-Out: https://privacy.openai.com/policies?modal=select-subject.
- Google Gemini API: Interface access (so-called "API") to AI-based services designed to
understand and generate natural language and related inputs, analyze information, and make predictions ("AI",
i.e., "Artificial Intelligence", is to be understood in the legal sense of the term as applicable). The
provision of AI services includes the processing (including collection, storage, organization, and structuring)
of personal data as part of a machine learning process based on natural language; conducting activities to
verify or maintain the quality of the services; identifying and correcting errors that impair the existing
intended functionality, as well as supporting efforts to ensure the security and integrity of the AI services;
Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Website: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Irland;
Privacy Policy: https://cloud.google.com/; Data Processing Agreement: https://business.safety.google/processorterms/?hl=de. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/processorterms/?hl=de), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://business.safety.google/processorterms/?hl=de).
- Microsoft Azure OpenAI Service: Interface access (so-called "API") to AI-based services
designed to understand and generate natural language and related inputs, analyze information, and make
predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the legal sense of the term as
applicable). The provision of AI services includes the processing (including collection, storage, organization,
and structuring) of personal data as part of a machine learning process based on natural language; conducting
activities to verify or maintain the quality of the services; identifying and correcting errors that impair the
existing intended functionality, as well as supporting efforts to ensure the security and integrity of the AI
services; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South
County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis:
Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://azure.microsoft.com/de-de/products/ai-foundry/models/openai/; Privacy
Policy: https://www.microsoft.com/en-us/privacy/privacystatement; Data Processing
Agreement: https://azure.microsoft.com/en-us/support/legal/. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/de-de/support/legal/), Switzerland - Data Privacy Framework
(DPF), Standard Contractual Clauses (https://azure.microsoft.com/de-de/support/legal/).
Cloud Services
We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a
Service") provided on the servers of its providers for the storage and management of content (e.g. document storage
and management, exchange of documents, content and information with certain recipients or publication of content and
information).
Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is
part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This
data may include in particular master data and contact data of data subjects, data on processes, contracts, other
proceedings and their contents. Cloud service providers also process usage data and metadata that they use for
security and service optimization purposes.
If we use cloud services to provide documents and content to other users or publicly accessible websites, forms,
etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case
of media control).
- Processed data types: Inventory data (For example, the full name, residential address, contact
information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content
data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as
details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths,
intensity and frequency of use, types of devices and operating systems used, interactions with content and
features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved
parties).
- Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters,
etc.); Business and contractual partners; Users (e.g. website visitors, users of online services). Third
parties.
- Purposes of processing: Office and organisational procedures; Information technology
infrastructure (Operation and provision of information systems and technical devices, such as computers,
servers, etc.)); Organisational and Administrative Procedures. Business processes and management procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Further information on processing methods, procedures and services used:
- Google Cloud Services: Cloud infrastructure services and cloud-based application software;
Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland;
Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further
Information: https://cloud.google.com/privacy.
- Cloud Firestore: Storage and real-time synchronization of data between clients and the cloud.
Offline access to data. Support for complex queries, transactions, and automatic scaling. Securing data through
integrated security rules and authentication methods; Service provider: Google Cloud EMEA
Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Legitimate
Interests (Article 6 (1) (f) GDPR); Website: https://firebase.google.com/products/storage; Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
- Cloud Storage for Firebase: Storage and retrieval of user data, including files such as images
and videos. Synchronisation of data across different devices. Management of access rights and security rules for
files. Integration with other Firebase services to support app development; Service provider:
Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal
Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://firebase.google.com/products/storage; Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
Web Analysis, Monitoring and Optimization
Web analytics (also referred to as "reach measurement") is used to evaluate the visitor flows of our online services
and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age
or gender. Through reach analysis, we can, for example, identify when our online services or their functions and
content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas
need optimization.
In addition to web analytics, we may also use testing procedures to test and optimize different versions of our
online services or their components.
Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these
purposes, and information can be stored in and later retrieved from a browser or device. The data collected
includes, in particular, visited websites and elements used on them, as well as technical information such as the
browser used, the computer system, and information about usage times. If users have given consent 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.
Additionally, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by
shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is
stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither
we nor the providers of the software used know the actual identity of the users, only the information stored in
their profiles for the respective procedures.
Legal basis information: If we ask users for their consent to use third-party providers, the legal basis for data
processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., our interest in
efficient, economic, and user-friendly services). In this context, we would also like to point out the information
on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features).
Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning
visitors); Profiles with user-related information (Creating user profiles). Provision of our online services and
usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise
stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f)
GDPR).
Further information on processing methods, procedures and services used:
- Firebase: Google Firebase is a platform for developers of apps for mobile devices and websites.
Google Firebase offers a variety of features for testing apps, monitoring their functionality and optimizing
them (shown on the following overview page: https://firebase.google.com/products).The functions include the storage of apps
including personal data of the application users, such as content created by them or information regarding their
interaction with the apps (so-called "cloud computing"). Google Firebase also offers interfaces that allow
interaction between the users of the app and other services, e.g. authentication using services such as
Facebook, Twitter or an e-mail password combination; Service provider: Google Ireland Limited,
Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Article 6
(1) (a) GDPR); Website: https://firebase.google.com; Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country
transfers: EEA - Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause), Switzerland - Data Privacy
Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).
- Google Analytics: We use Google Analytics to perform measurement and analysis of the use of our
online services by users based on a pseudonymous user identification number. This identification number does not
contain any unique data, such as names or email addresses. It is used to assign analysis information to an end
device in order to recognize which content users have accessed within one or various usage processes, which
search terms they have used, have accessed again or have interacted with our online services. Likewise, the time
of use and its duration are stored, as well as the sources of users referring to our online services and
technical aspects of their end devices and browsers.
In the process, pseudonymous profiles of users are
created with information from the use of various devices, and cookies may be used. Google Analytics does not log
or store individual IP addresses. Analytics does provide coarse geo-location data by deriving the following
metadata from IP addresses: City (and the derived latitude, and longitude of the city), Continent, Country,
Region, Subcontinent (and ID-based counterparts). For EU-based traffic, IP-address data is used solely for
geo-location data derivation before being immediately discarded. It is not logged, accessible, or used for any
additional use cases. When Analytics collects measurement data, all IP lookups are performed on EU-based servers
before forwarding traffic to Analytics servers for processing; Service provider: Google Ireland
Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent
(Article 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security
measures: IP Masking (Pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country
transfers: 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); Opt-Out:
Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of
Advertisements: https://myadcenter.google.com/personalizationoff. Further Information:
https://business.safety.google/adsservices/ (Types of processing and data processed).
Online Marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of
advertising space or the display of advertising and other content (collectively referred to as "Content") based on
the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar
procedure is used by which the relevant user information for the display of the aforementioned content is stored.
This information may include, for example, content viewed, websites visited, online networks used, communication
partners and technical information such as the browser used, computer system used and information on usage times and
used functions. If users have consented to the collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation
by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the
framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but
pseudonyms. This means that we, as well as the providers of 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 similar memorizing procedures. These cookies can
later, generally also on other websites that use the same online marketing technology, be read and analyzed for
purposes of content display, as well as supplemented with other data and stored on the server of the online
marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of
a social network whose online marketing technology we use and the network links the profiles of the users in the
aforementioned data. Please note that users may enter into additional agreements with the social network providers
or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements.
However, within the framework of so-called conversion measurement, we can check which of our online marketing
processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion
measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.
Notes on revocation and objection:
We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called
"opt-out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings
of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following
additional opt-out options, which are offered collectively for each area:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://optout.aboutads.info.
d) Cross-regional: https://optout.aboutads.info.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features).
Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning
visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Affiliate Tracking;
Marketing. Profiles with user-related information (Creating user profiles).
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise
stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Security measures: IP Masking (Pseudonymization of the IP address).
- Legal Basis: Consent (Article 6 (1) (a) GDPR).
Further information on processing methods, procedures and services used:
Profiles in Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context in order to communicate
with the 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 entail risks for
users, e.g. by making it more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For
example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user
profiles can then be used, for example, to place advertisements within and outside the networks which are presumed
to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer,
in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles
independently of the devices used by the users (especially if the users are members of the respective networks or
will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the
respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can
be most effectively pursued with the providers. Only the providers have access to the data of the users and can
directly take appropriate measures and provide information. If you still need help, please do not hesitate to
contact us.
- Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content
data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as
details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths,
intensity and frequency of use, types of devices and operating systems used, interactions with content and
features).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form).
Public relations.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that are obtained from the servers of their
respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics,
videos or city maps (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of this content process the IP address of the user,
since they could not send the content to their browser without the IP address. The IP address is therefore required
for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers
use the IP address only for the distribution of the contents. Third parties 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 evaluate 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 include technical information about the browser and operating
system, referring websites, visit times and other information about the use of our website, as well as may be linked
to such information from other sources.
- Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity
and frequency of use, types of devices and operating systems used, interactions with content and features).
Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online services and usability.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise
stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f)
GDPR).
Further information on processing methods, procedures and services used:
- Wikimedia: Our app allows users to search for and display images from Wikimedia Commons. To do
this, the app sends requests to the Wikimedia API. In this process, the user's IP address and technical metadata
are transmitted to Wikimedia servers.
This data transfer is necessary to display the requested content
and is based on our legitimate interest in providing this functionality (Art. 6(1)(f) GDPR). We do not store or
process this data ourselves. Wikimedia may process it according to its Privacy Policy; Service
provider: Wikimedia Foundation, Inc; Website: https://foundation.wikimedia.org/wiki/Home. Privacy Policy: https://foundation.wikimedia.org/wiki/Policy:Privacy_policy.
- Embedding of Third Party Content: Courses provided through our app may include content from
external sources (third parties), such as images, videos, stylesheets, or scripts that are not hosted on our
servers but are instead loaded directly from the respective third-party provider.
Loading such content
technically requires your IP address to be transmitted to the third party, as this is necessary to deliver the
content to your device. Third-party providers may also use cookies or other tracking technologies.
To
protect your privacy, we only load external content if you have explicitly consented to it. You can configure in
the app settings whether third-party content should be displayed. This option is disabled by default. You can
withdraw your consent at any time through the app settings.
Depending on the type of embedded content,
data may be transferred to third countries (e.g., the USA), where an adequate level of data protection
equivalent to that in the EU may not be guaranteed.
Legal basis: Art. 6 para. 1 lit. a GDPR
(consent)
Purpose of processing: Display of embedded content within courses.
- Openverse API: Our app allows users to search for and display images from the Openverse API. To
do this, the app sends requests to the Openverse API. In this process, the user's IP address and technical
metadata are transmitted to Openverse servers.
This data transfer is necessary to display the requested
content and is based on our legitimate interest in providing this functionality (Art. 6(1)(f) GDPR). We do not
store or process this data ourselves. Openverse may process it according to its Privacy Policy; Service
provider: WordPress Foundation, 660 4th Street, Box 119, San Francisco, CA 94107, United States;
Website: https://openverse.org/.
Privacy Policy: https://wordpress.org/about/privacy/.
Management, Organization and Utilities
We use services, platforms and software from other providers (hereinafter referred to as " third-party providers")
for the purposes of organizing, administering, planning and providing our services. When selecting third-party
providers and their services, we comply with the legal requirements.
Within this context, personal data may be processed and stored on the servers of third-party providers. This may
include 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 processes, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the context of communication,
business or other relationships with us, the third-party provider processing may process usage data and metadata
that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask
you to read the data protection notices of the respective third party providers.
- Processed data types: Content data (e.g. textual or pictorial messages and contributions, as
well as information pertaining to them, such as details of authorship or the time of creation.); Usage data
(e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and
operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP
addresses, timestamps, identification numbers, involved parties).
- Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Users (e.g.
website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfillment of contractual
obligations. Office and organisational procedures.
- Retention and deletion: Deletion in accordance with the information provided in the section
"General Information on Data Retention and Deletion".
- Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Changes and Updates
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust
the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as
the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to
note that addresses may change over time and to verify the information before contacting us.
Terminology and Definitions
In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is
legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid
understanding.
- Affiliate Tracking: Custom Audiences refers to the process of determining target groups for
advertising purposes, e.g. the display of advertisements. For example, a user's interest in certain products or
topics on the Internet may be used to conclude that the user is interested in advertisements for similar
products or the online store in which the user viewed the products. "Lookalike Audiences" is the term used to
describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the
users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences,
cookies and web beacons are typically used.
- Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence
(AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and
improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of
data, training and applying AI models, as well as the continuous review and optimisation of results, and is
carried out exclusively with users' consent or based on legal authorisation grounds.
- Contact data: Contact details are essential information that enables communication with
individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses,
as well as means of communication like social media handles and instant messaging identifiers.
- Content data: Content data comprise information generated in the process of creating, editing,
and publishing content of all types. This category of data may include texts, images, videos, audio files, and
other multimedia content published across various platforms and media. Content data are not limited to the
content itself but also include metadata providing information about the content, such as tags, descriptions,
authorship details, and publication dates.
- Contract data: Contract data are specific details pertaining to the formalisation of an
agreement between two or more parties. They document the terms under which services or products are provided,
exchanged, or sold. This category of data 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 encompass the start and end dates of the contract, the nature of the agreed-upon
services or products, pricing arrangements, payment terms, termination rights, extension options, and special
conditions or clauses. They serve as the legal foundation for the relationship between the parties and are
crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
- 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.
- Employees: As employees, individuals are those who are engaged in an employment relationship,
whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an
employer and an employee, established through an employment contract or agreement. It entails the obligation of
the employer to pay the employee remuneration while the employee performs their work. The employment
relationship encompasses various stages, including establishment, where the employment contract is concluded,
execution, where the employee carries out their work activities, and termination, when the employment
relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all
information pertaining to these individuals within the context of their employment. This includes aspects such
as personal identification details, identification numbers, salary and banking information, working hours,
holiday entitlements, health data, and performance assessments.
- Inventory data: Inventory data encompass essential information required for the identification
and management of contractual partners, user accounts, profiles, and similar assignments. These data may
include, among others, personal and demographic details such as names, contact information (addresses, phone
numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation
for any formal interaction between individuals and services, facilities, or systems, by enabling unique
assignment and communication.
- Log data: Protocol data, or log data, refer to information regarding events or activities that
have been logged within a system or network. These data typically include details such as timestamps, IP
addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol
data is often used for analyzing system issues, monitoring security, or generating performance reports.
- Meta, communication and process data: Meta-, communication, and procedural data are categories
that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data
about data, include information that describes the context, origin, and structure of other data. They can
include details about file size, creation date, the author of a document, and modification histories.
Communication data capture the exchange of information between users across various channels, such as email
traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps,
and transmission paths. Procedural data describe the processes and operations within systems or organisations,
including workflow documentations, logs of transactions and activities, and audit logs used for tracking and
verifying procedures.
- Payment Data: Payment data comprise all information necessary for processing 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 information, payment
amounts, transaction dates, verification numbers, and billing information. Payment data may also contain
information on payment status, chargebacks, authorizations, and fees.
- Personal Data: "personal data" means any information relating to an identified or identifiable
natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
- Processing: The term "processing" covers a wide range and practically every handling of data,
be it collection, evaluation, storage, transmission or erasure.
- Profiles with user-related information: The processing of "profiles with user-related
information", or "profiles" for short, includes any kind of automated processing of personal data that consists
of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural
person (depending on the type of profiling, this may include different information concerning demographics,
behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain
content or products, click behaviour on a website or location). Cookies and web beacons are often used for
profiling purposes.
- Targeting: "Tracking" is the term used when the behaviour of users can be traced across several
websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or
on the servers of the tracking technology providers (so-called profiling). This information can then be used,
for example, to display advertisements to users presumably corresponding to their interests.
- Usage data: Usage data refer to information that captures how users interact with digital
products, services, or platforms. These data encompass a wide range of information that demonstrates how users
utilise applications, which features they prefer, how long they spend on specific pages, and through what paths
they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP
addresses, device information, and location data. They are particularly valuable for analysing user behaviour,
optimising user experiences, personalising content, and improving products or services. Furthermore, usage data
play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings
- Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and
can determine their behavior or interests in certain information, such as content of websites. With the help of
web analytics, website owners, for example, can recognize at what time visitors visit their website 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 web analytics , pseudonymous cookies and web beacons are often
used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.