Privacy Policy

Legal

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this
Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance, be information
you enter into our contact form.

Other data shall be recorded by our IT systems automatically, or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyse your user patterns.

What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have
the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection
related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analysed when you visit this website.
Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs, please consult our Data Protection Declaration
below.

2. Hosting

We are hosting the content of our website at the following provider:

All-Inkl

The Provider is the ALL-INKL.COM – Neue Medien Münnich, owner: René Münnich, Hauptstraße 68, 02742
Friedersdorf, Germany (hereinafter “All-Inkl”). For details, please visit the privacy policy of All-Inkl:
https://all-inkl.com/datenschutzinformationen/.

The use of All-Inkl is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable
representation of our website. If appropriate consent has been obtained, the processing is carried out
exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of
cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning
of the TDDDG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the
information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:
Wakonda Ventures B.V.
dourovista
Keizersgracht 520
1017 EK, Amsterdam
Netherlands

E-mail: hello@dourovista.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or
Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of
explicit consent to the transfer of personal data to third countries, the data processing, is also based on Art.
49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end
device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The
consent can be revoked at any time. If your data is required for the fulfilment of a contract or for the
implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR.
Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art.
6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in
the following paragraphs of this privacy policy.

Information on the data transfer to third-party countries that are not secure under data
protection law and the transfer to US companies that are not DPF-certified

We use, among other technologies, tools from companies located in third-party countries that are not safe
under data protection law, as well as US tools whose providers are not certified under the EU-US Data
Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and
processed in these countries. We would like you to note that no level of data protection comparable to that
in the EU can be guaranteed in third countries that are insecure in terms of data protection law.

We would like to point out that the US, as a secure third-party country, generally has a level of data
protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is
certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances.
Information on transfers to third-party countries, including the data recipients, can be found in this Privacy
Policy.

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also
requires the transfer of personal data to these external parties. We only disclose personal data to external
parties if this is required as part of the fulfilment of a contract, if we are legally obligated to do so (e.g.,
disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f)
GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose
personal data of our customers on the basis of a valid contract on data processing. In the case of joint
processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible, only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness
of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct
advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE
THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED
ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS
BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE
WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,
THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE
PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION
PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL
DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES
(OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of
a contract handed over to you or to a third party in a common, machine-readable format. If you should
demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about
your archived personal data, their source and recipients as well as the purpose of the processing of your data
at any time. You may also have a right to have your data rectified or eradicated. If you have questions about
this subject matter or any other questions about personal data, please do not hesitate to contact us at any
time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in
the following cases:

In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead
of its eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the
right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving –
may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by
the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this
information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are
processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by
checking whether the address line of the browser switches from “http://” to “https://” and also by the
appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you
share with us.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory
information to be provided in our Site Notice to send us promotional and information material that we have
not expressly requested. The operators of this website and its pages reserve the express right to take legal
action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do
not cause any damage to your device. They are either stored temporarily for the duration of a session
(session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are
automatically deleted once you terminate your visit. Permanent cookies remain archived on your device
until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies).
Third-party cookies enable the integration of certain services of third-party companies into websites (e.g.,
cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos).
Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision
of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the
optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web
audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The
operator of the website has a legitimate interest in the storage of required cookies to ensure the technically
error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies
and similar recognition technologies has been requested, the processing occurs exclusively on the basis of
the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are
placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of
cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies
when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

CookieFirst

Our website uses CookieFirst to obtain your consent to the storage of certain cookies on your device or to
use certain technologies and document them in a privacy-compliant manner. The provider of this technology
is Digital Data Solutions B.V. (CookieFirst), Plantage Middenlaan 42A, 1018 DH Amsterdam, The
Netherlands (hereinafter “CookieFirst”).

When you enter our website, a connection to CookieFirst's servers is established to obtain your consent and
other statements regarding cookie use. CookieFirst then stores a cookie in your browser in order to be able
to assign the consents granted to you or their revocation. In this process, the IP address (anonymized), the
user agent of the browser and operating system, as well as the URL from which the consent was granted, are
processed and integrated into CookieFirst. The data collected in this way is stored until you request us to
delete it, delete the CookieFirst cookie yourself or the purpose for storing the data no longer applies.
Mandatory statutory retention obligations remain unaffected.

CookieFirst transfers personal data to third-party providers. These include a CDN from Slovenia, IP
geolocation from Romania, and hosting at OHV in Germany and France. CookieFirst has its corporate
headquarters in Amsterdam, the Netherlands.

We use CookieFirst to obtain the consent required by law for the use of cookies from site visitors. The legal
basis for this is Art. 6(1)(1)(c) GDPR.

Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a
contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server
log files, which your browser communicates to us automatically. The information comprises:

The type and version of browser used
The used operating system
Referrer URL
The hostname of the accessing computer
The time of the server inquiry
The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest
in the technically error free depiction and the optimization of the operator’s website. In order to achieve this,
server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any
contact information provided therein will be stored by us in order to handle your inquiry and in the event
that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based
on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the
data, revoke your consent to the archiving of data or if the purpose for which the information is being
archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without
prejudice to any mandatory legal provisions, in particular retention periods.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a
contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be
revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Google Forms

We have integrated Google Forms into this website. The provider is Google Ireland Limited, Gordon House,
Barrow Street, Dublin 4, Ireland (hereinafter referred to as „Google”).

Google Forms enables us to generate online forms to record messages, inquiries and other entries entered
by visitors to our website. All entries you make will be processed on Google’s servers. Google Forms stores a
cookie in your browser that contains a unique ID (NID cookie). This cookie stores a wide range of
information, including, for example your language settings.

We use Google Forms on the basis of our legitimate interest in determining your needs as effectively as
possible (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out
exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of
cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning
of the TDDDG. This consent can be revoked at any time.

The data you enter into the form will remain in our possession until you ask us to delete them, revoke your
consent to the archiving of your data or until the purpose of archiving the data no longer exists (e.g., upon
completion of the processing of your inquiry). This does not affect mandatory statutory provisions – in
particular those governing retention periods.

For more information, please consult Google’s Data Privacy Policy at
https://policies.google.com/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5780.

Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website
visitors only based on our instructions and in compliance with the GDPR.

5. Social media

Instagram

We have integrated functions of the public media platform Instagram into this website. These functions are
being offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

If the social media element has been activated, a direct connection between your device and Instagram’s
server will be established. As a result, Instagram will receive information on your visit to this website.

If you are logged into your Instagram account, you may click the Instagram button to link contents from this
website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user
account. We have to point out that we as the provider of the website and its pages do not have any
knowledge of the content of the data transferred and its use by Instagram.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG.
Consent can be revoked at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to
Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal
Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint
responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram.
The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint
responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The
wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for
providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure
implementation of the tool on our website. Facebook is responsible for the data security of Facebook or
Instagram products. You can assert data subject rights (e.g., requests for information) regarding data
processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we
are obliged to forward them to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://privacycenter.instagram.com/policy/ and
https://de-de.facebook.com/help/566994660333381.

For more information on this subject, please consult Instagram’s Data Privacy Declaration at:
https://privacycenter.instagram.com/policy/.

This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s
servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click
on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in
a position to allocate your visit to this website to your user account. We have to point out that we as the
provider of the websites do not have any knowledge of the content of the transferred data and its use by
LinkedIn.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG.
Consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-undder-
schweiz?lang=de.

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at:
https://www.linkedin.com/legal/privacy-policy.

6. Analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other
technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store
cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via
it. However, the Google Tag Manager does collect your IP address, which may also be transferred to
Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the quick and uncomplicated integration and administration of various tools on his website. If
appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a)
GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information
in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be
revoked at any time.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that
end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the
utilized operating system and the user’s origin. This data is summarized in a user-ID and assigned to the
respective end device of the website visitor.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among
other things. Google Analytics uses various modeling approaches to augment the collected data sets and
uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the
user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by
Google is, as a rule transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization
Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within
the member states of the European Union or in other states that have ratified the Convention on the
European Economic Area prior to its transmission to the United States. The full IP address will be
transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases.
On behalf of the operator of this website, Google shall use this information to analyze your use of this
website to generate reports on website activities and to render other services to the operator of this website
that are related to the use of the website and the Internet. The IP address transmitted in conjunction with
Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the
browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data
Privacy Declaration at:
https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent
provisions of the German data protection agencies to the fullest when using Google Analytics.

Microsoft Advertising

The website operator uses Microsoft Advertising. Microsoft Advertising is an online advertising program of
Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

Microsoft Advertising enables us to display advertisements in the Bing search engine or on third-party
websites when the user enters certain search terms into Bing (keyword targeting). Furthermore, targeted
advertisements can be displayed based on the user data available at Microsoft (e.g., location data and
interests) (target group targeting). As the website operator, we can evaluate this data quantitatively by
analyzing, for example, which search terms led to the display of our advertisements and how many
advertisements led to the corresponding clicks.

We use universal event tracking (UET) from Microsoft Advertising on this site. Pseudonymized data is
collected to track the actions you take on our websites after you have clicked on an advertisement of
Microsoft Advertising. UET collects your IP address (anonymized), device identifiers, information about
device and browser settings, Microsoft Click ID (stored in cookie), time spent on the website, which areas of
the website were accessed, which advertisement brought you to the website and which keyword you clicked
on.

The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG.
Consent can be revoked at any time.

Data transfer to the US is based on the standard contractual clauses of the EU Commission. You can find
details here:
https://learn.microsoft.com/de-de/compliance/regulatory/offering-eu-model-clauses.

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland
Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user
enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based
on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the
website operator, we can analyze these data quantitatively, for instance by analyzing which search terms
resulted in the display of our ads and how many ads led to respective clicks.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://policies.google.com/privacy/frameworks and
https://business.safety.google/controllerterms/.

Google Ads Remarketing

This website uses the functions of Google Ads Remarketing. The provider of these solutions is Google
Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads Remarketing, we can assign people who interact with our online offering to specific target
groups in order to subsequently display interest-based advertising to them in the Google advertising
network (remarketing or retargeting).

Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to
device encompassing functions of Google. This makes it possible to display interest-based customized
advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a
manner tailored to you as well as on any of your devices (e.g., tablet or PC).

If you have a Google account, you have the option to object to personalized advertising under the following
link:
https://adssettings.google.com/anonymous?hl=de.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.

For further information and the pertinent data protection regulations, please consult the Data Privacy
Policies of Google at:
https://policies.google.com/technologies/ads?hl=en.

Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we use, among other things, the Google Ads Remarketing customer
reconciliation feature. To achieve this, we transfer certain customer data (e.g., email addresses) from our
customer lists to Google. If the respective customers are Google users and are logged into their Google
accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search
engine) are displayed for them to view.

Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has
completed certain actions. For instance, we can analyze the how frequently which buttons on our website
have been clicked and which products are reviewed or purchased with particular frequency. The purpose of
this information is to compile conversion statistics. We learn how many users have clicked on our ads and
which actions they have completed. We do not receive any information that would allow us to personally
identify the users. Google as such uses cookies or comparable recognition technologies for identification
purposes.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1)
TDDDG. You may revoke your consent at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at:
https://policies.google.com/privacy?hl=en

7. Newsletter

Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail
address as well as information that allow us to verify that you are the owner of the e-mail address provided
and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a
voluntary basis. We shall use such data only for the sending of the requested information and shall not share
such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on
the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of
data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for
instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the
lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you
unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter
distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We
reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own
discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the
newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data
from the blacklist is used only for this purpose and not merged with other data. This serves both your
interest and our interest in complying with the legal requirements when sending newsletters (legitimate
interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to
the storage if your interests outweigh our legitimate interest.

Newsletter mailing to existing customers

If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently
be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct
advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from
this newsletter at any time. There is a corresponding link in every newsletter for this purpose. In this case,
the legal basis for sending the newsletter is Art. 6 (1)(f) GDPR in conjunction with Section 7 (3) UWG.

After you unsubscribe from the newsletter distribution list, we may store your email address in a blacklist to
prevent future mailings to you. The data from the blacklist will only be used for this purpose and will not be
merged with other data. This serves both your interest and our interest in complying with the legal
requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1)(f) GDPR).
Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our
legitimate interest.

8. Plug-ins and Tools

SolidWP

We have integrated SolidWP into this website. The provider is iThemes Media LLC, 1720 South Kelly
Avenue Edmond, OK 73013, USA (hereinafter referred to as “SolidWP”).

SolidWP protects our website against undesirable access or malicious cyber-attacks. For this purpose,
SolidWP records, among other things, your IP address, the time, and source of login attempts and log files
(e.g., the utilized browser). SolidWP is installed locally on our servers.

SolidWP transmits IP addresses of recurring attackers to a central database of SolidWP in the US (Network
Brute Force Protection) to prevent such attacks in the future.

The use of SolidWP is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in
protecting its website optimally against cyber-attacks. If appropriate consent has been obtained, the
processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the
consent includes the storage of cookies or the access to information in the user’s end device (e.g., device
fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.

9. eCommerce and payment service providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content
arrangement and modification of our contractual relationships. Data with personal references to the use of
this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to
use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.

The collected customer data shall be deleted upon completion of the order or termination of the business
relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice
to any statutory archiving periods.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the
contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the
transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for
advertising purposes, shall not occur.

The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the
fulfilment of a contract or for pre-contractual actions.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from
us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed
by the payment service provider for the purpose of payment processing. For these transactions, the
respective contractual and data protection provisions of the respective providers apply. The use of the
payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a
smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is
requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be
revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Stripe
The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand
Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://stripe.com/de/privacy and
https://stripe.com/de/guides/general-data-protection-regulation.

Details can be found in Stripe’s Privacy Policy at the following link:
https://stripe.com/de/privacy.

10. Online-based Audio and Video Conferences (Conference
tools)

Data processing
We use online conference tools, among other things, for communication with our customers. The tools we
use are listed in detail below. If you communicate with us by video or audio conference using the Internet,
your personal data will be collected and processed by the provider of the respective conference tool and by
us. The conferencing tools collect all information that you provide/access to use the tools (email address
and/or your phone number). Furthermore, the conference tools process the duration of the conference, start
and end (time) of participation in the conference, number of participants and other “context information”
related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the
online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type,
operating system type and version, client version, camera type, microphone or loudspeaker and the type of
connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the
servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant
messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our
possibilities are largely determined by the corporate policy of the respective provider. Further information
on data processing by the conference tools can be found in the data protection declarations of the tools
used, and which we have listed below this text.

Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer
certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally
simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art.
6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this
consent; the consent may be revoked at any time with effect from that date.

Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems
immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the
data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal
retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the
conference tools for their own purposes. For details, please directly contact the operators of the conference
tools.

Conference tools used
We employ the following conference tools:

Google Meet

We use Google Meet. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4,
Ireland. For details on data processing, please see the Google privacy policy:
https://policies.google.com/privacy?hl=en.

Privacy Policy

1. An overview of data protection

General information

Data recording on this website

Analysis tools and tools provided by third parties

2. Hosting

All-Inkl

3. General information and mandatory information

Data protection

Information about the responsible party (referred to as the “controller” in the GDPR)

Storage duration

General information on the legal basis for the data processing on this website

Information on the data transfer to third-party countries that are not secure under dataprotection law and the transfer to US companies that are not DPF-certified

Recipients of personal data

Revocation of your consent to the processing of data

Right to object to the collection of data in special cases; right to object to directadvertising (Art. 21 GDPR)

Right to log a complaint with the competent supervisory agency

Right to data portability

Information about, rectification and eradication of data

Right to demand processing restrictions

SSL and/or TLS encryption

Encrypted payment transactions on this website

Rejection of unsolicited e-mails

4. Recording of data on this website

Cookies

CookieFirst

Server log files

Contact form

Request by e-mail, telephone, or fax

Google Forms

5. Social media

Instagram

LinkedIn

6. Analysis tools and advertising

Google Tag Manager

Google Analytics

Microsoft Advertising

Google Ads

Google Ads Remarketing

Google Conversion-Tracking

7. Newsletter

Newsletter data

Newsletter mailing to existing customers

8. Plug-ins and Tools

SolidWP

9. eCommerce and payment service providers

Processing of Customer and Contract Data

Data transfer upon closing of contracts for services and digital content

Payment services

10. Online-based Audio and Video Conferences (Conferencetools)

Google Meet

Company

Legal

Information on the data transfer to third-party countries that are not secure under data
protection law and the transfer to US companies that are not DPF-certified

Right to object to the collection of data in special cases; right to object to direct
advertising (Art. 21 GDPR)

10. Online-based Audio and Video Conferences (Conference
tools)