Privacy policy

Introduction

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of 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 offer").

The terms used are not gender-specific.

Status: August 6, 2020

Table of contents

• Introduction
• Person responsible
• Overview of processing
• Relevant legal bases
• Security measures
• Data processing in third countries
• Use of cookies
• Commercial and business services
• Payment service provider
• Provision of the online offer and web hosting
• Registration, login and user account
• Contact us
• Video conferences, online meetings, webinars and screen sharing
• Surveys and interviews
• Web analysis, monitoring and optimization
• Online marketing
• Plugins and embedded functions and content
• Deletion of data
• Amendment and updating of the privacy policy
• Rights of the data subjects
• Definitions of terms

Person responsible

fingerLINK
Nicole Szálasi
Old fairground 1
96135 Stegaurach

Persons authorized to represent the company: Nicole Szálasi

E-mail address: info@fingerlink.com

Phone: Phone: +49 951 299 520 85

Imprint: https://fingerlink.com/impressum/

Overview of processing

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

Types of data processed

• Inventory data (e.g. names, addresses).
• Content data (e.g. text input).
• Contact details (e.g. e-mail, telephone numbers).
• Meta/communication data (e.g. device information, IP addresses).
• Usage data (e.g. websites visited, interest in content, access times).
• Contract data (e.g. subject matter of the contract, term, customer category).
• Payment data (e.g. bank details, invoices, payment history).

Categories of affected persons

• Business and contractual partners.
• Interested parties.
• Communication partner.
• Customers.
• Users (e.g. website visitors, users of online services).

Purposes of the processing

• Provision of our online services and user-friendliness.
• Visit action evaluation.
• Office and organizational procedures.
• Direct marketing (e.g. by e-mail or post).
• Feedback (e.g. collecting feedback via online form).
• Interest-based and behavioral marketing.
• Contact requests and communication.
• Conversion measurement (measurement of the effectiveness of marketing measures).
• Profiling (creation of user profiles).
• Remarketing.
• Reach measurement (e.g. access statistics, recognition of returning visitors).
• Safety measures.
• Tracking (e.g. interest/behavioral profiling, use of cookies).
• Contractual benefits and service.
• Managing and responding to inquiries.

Relevant legal bases

In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
• Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - Processing is necessary for the 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.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in GermanyIn addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. The data protection laws of the individual federal states may also apply.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection 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 the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https)In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de/ ).

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs")

A distinction is made between the following cookie types and functions:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
• Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users that are used for reach measurement or marketing purposes can also be stored in such a cookie.
• First-party cookies: First-party cookies are set by us.
• Third-party cookies (also: third-party cookies)Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
• Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
• Statistics, marketing and personalization cookiesCookies are also generally used to measure reach and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e. tracing the potential interests of users. . If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage duration: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). You can also object to the use of cookies for online marketing purposes by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be declared. You can also receive further information on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consentBefore we process or have data processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies that are absolutely necessary for the operation of our online offer will be used.

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

You can view and change your cookie settings at any time via the Privacy & Cookies Policy button at the bottom right.

Commercial and business services

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

We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.

We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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

Participant account: Contractual partners can create an account within our online offering (e.g. participant or user account, "participant account" for short). If the registration of a subscriber account is required, contractual partners will be informed of this and of the information required for registration. Participant accounts are not public and cannot be indexed by search engines. As part of the registration process and subsequent logins and use of the subscriber account, we store the IP addresses of customers together with the access times in order to be able to prove registration and prevent any misuse of the subscriber account.

Participant accounts have a license period of 180 days. One year after expiry of this license period, participant accounts are automatically deleted, unless their retention is required for legal reasons. Former participants have the option of reactivating their account at a reduced rate within this period.

Education and training servicesWe process the data of participants in our education and training programs (uniformly referred to as "trainees") in order to be able to provide them with our training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of our instructors.

As part of our activities, we may also process special categories of data, in particular information on the health of trainees and data revealing ethnic origin, political opinions, religious or philosophical beliefs. Where necessary, we obtain the express consent of the trainees for this and otherwise only process the special categories of data if it is necessary for the provision of training services, for the purposes of health care, social protection or the protection of vital interests of the trainees.

If it is necessary for the fulfillment of our contract, for the protection of vital interests or by law, or if the consent of the trainees has been obtained, we disclose or transfer the data of the trainees to third parties or agents, such as authorities or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

• Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), website usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Interested parties, business and contractual partners, customers.
• Purposes of the processing: Contractual performance and service, contact requests and communication, office and organizational procedures, administration and response to requests, security measures.
• Legal basis: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment service provider

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as 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 by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about 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 general terms and conditions and the data protection information of the payment service providers.

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

• Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Customers, interested parties.
• Purposes of the processing: Contractual benefits and service.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

• Stripe: Payment services; Service provider: Stripe, Inc, 510 Townsend Street, San Francisco, CA 94103, USA; Website: https://stripe.com/de/ ; Privacy policy: https://stripe.com/de/privacy.

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that is generated during use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log filesWe ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

Services used and service providers:

• Sentry: Monitoring of system stability and detection of code errors - Information on the device or time of error is collected pseudonymously and is subsequently deleted; Service provider: Functional Software Inc, Sentry, 132 Hawthorne Street, San Francisco, California 94107, USA; Website: https://sentry.ioSecurity measures: IP masking (pseudonymization of the IP address); Privacy policy: https://sentry.io/privacy.

• Server of Hetzner Online GmbH

The data entered by you will remain on the servers in the data center of Hetzner Online GmbH, Industriestrasse 25 in 91710 Gunzenhausen until you request us to delete it or until we delete it in accordance with the aforementioned period. The legality of the data processing operations already carried out remains unaffected by the revocation. Mandatory statutory provisions - in particular retention periods - remain unaffected. Further information on how Hetzner Online GmbH handles personal data can be found in the privacy policy at https://www.hetzner.de/rechtliches/datenschutz.

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users can be informed by email about processes that are relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to a statutory retention obligation. It is the responsibility of users to back up 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.

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

• Processed data types: Master data (e.g. names, addresses, date of birth), contact data (e.g. email), contract data (e.g. subject matter of the contract, term, customer category), usage data fingerLINK online exercise book (learning progress, statistical evaluation of learning success), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Purposes of the processing: Contractual services and service, security measures, administration and answering inquiries.
• Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of the legitimate interests in responding to the inquiries.

• Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
• Persons concerned: Communication partner.
• Purposes of the processing: Contact requests and communication.
• Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Video conferences, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as "third-party providers") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen content.

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 providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to the use of third-party providers or certain functions (e.g. consent to the recording of conversations), the legal basis for processing is consent. Furthermore, their use may be part of our (pre-)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Microsoft Teams:

• Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
• Purposes of the processing: Contractual services and service, contact requests and communication, office and organizational procedures.
• Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services used and service providers:

• Microsoft Teams: Messenger and conference software; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.comPrivacy policy: https://privacy.microsoft.com/de-de/privacystatementSafety instructions: https://www.microsoft.com/de-de/trustcenter.

Surveys and interviews

The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the help of a temporary cookie (session cookie)) or if users have given their consent.

Notes on legal bases: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants' data is based on our legitimate interests in conducting an objective survey.

• Processed data types: Content data (e.g. text entries, photographs), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Participants.
• Purposes of the processing: Quality assurance, feedback (e.g. collecting feedback via online form).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Web analysis, monitoring and optimization

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

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

For these purposes, so-called user profiles can be created and stored in a file (so-called "cookie") or similar procedures with the same purpose can be used. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

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

Fullstory:

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioral profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
• Safety measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

• Fullstory: Website analysis service; Service provider: Fullstory, Inc, 818 Marietta Street, Atlanta, GA 30318, USA; Website: https://www.fullstory.comPrivacy policy: https://www.fullstory.com/legal/privacy/Possibility of objection (opt-out): https://www.fullstory.com/optout .

Online marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of its effectiveness.

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

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.

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

In exceptional cases, 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 processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

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

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

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

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Users (e.g. website visitors, users of online services), interested parties.
• Purposes of the processing: Tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
• Safety measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
• Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for the respective areas:a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

• Google Analytics: Online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/Privacy policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: https://adssettings.google.com/authenticated.
• Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are presumed to be interested in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called "conversion tracking tag". However, we ourselves do not receive any information that can be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.comPrivacy policy: https://policies.google.com/privacy.
• Google Tag Manager: To monitor the stability and performance of the system, Google Tag Manager can be used to collect aggregated tag triggering data. This data does not contain any IP addresses or other user-specific identifiers that could be assigned to a specific person. Unlike data in standard HTTP request logs, which are all deleted within 14 days of receipt, Google Tag Manager does not collect, store or share information about visitors to our customers' properties. This also applies to the URLs of visited pages. Further information on the use of Google Tag Manager data can be found in Google's terms of use: https://support.google.com/tagmanager/answer/7157428 .

Plugins and embedded functions and content

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as "content").

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

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

• Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Users (e.g. website visitors, users of online services).
• Purposes of the processing: Provision of our online offer and user-friendliness, contractual services and service.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services used and service providers:

• Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/Privacy policy: https://policies.google.com/privacy.
• ReCaptcha: We integrate the "ReCaptcha" function to recognize bots, e.g. when entering data in online forms. The user's behavioral data (e.g. mouse movements or queries) are evaluated in order to distinguish humans from bots. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/Privacy policy: https://policies.google.com/privacy; Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: https://adssettings.google.com/authenticated.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

Participant data is stored for one year as standard and then deleted. Within this period, participants have the option of reactivating their account at the discounted rate.

Amendment and updating of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

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

• Right of objection: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used 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 statutory provisions, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Supervisory authority responsible for us:

Bavarian State Office for Data Protection Supervision
Promenade 18
91522 Ansbach
Germany
https://www.lda.bayern.de

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.

• Visit action evaluation: "Conversion tracking" refers to a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful).
• IP masking: IP masking" refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing procedures, particularly in online marketing
• Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting certain websites and lingering on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
• Conversion measurement: Conversion measurement is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiling: "Profiling" refers to any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them to better adapt the content of the website to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
• Remarketing: Remarketing" or "retargeting" is when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
• Tracking: The term "tracking" is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
• Responsible person: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.