Privacy

This Privacy Policy provides information about which personal data is collected during individual processing operations and how and for what purposes this personal data is processed.

This Privacy Policy provides information on data processing when visiting the website, but also when using the Speed Kit dashboard and in other contexts, e.g. processing the data of customers, applicants and when participating in video conferences.

Your personal data will always be processed in accordance with the statutory data protection regulations and this Privacy Policy.

Controller is Baqend GmbH, Stresemannstraße 23, 22769 Hamburg, Germany, Tel. +49 (0)40 6094 0539, e-Mail: info@baqend.com (hereinafter „Baqend").

The data protection officer of the Controller, Rechtsanwalt Christian Schmoll, can be contacted at privacy@baqend.com.

3.1 Hosting and Log Files

Each time the website is accessed, the system automatically collects data and information from the computer system of the accessing end device. The following data is recorded or logged:

• IP address of the calling computer
• Operating system of the calling computer
• Browser version of the calling computer
• Name of the retrieved file/website
• Date and time of retrieval
• Transferred amount of data
• Referring URL

This data is processed in order to be able to present the website, to ensure the security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access by bots), to improve the quality and presentation of the website, to be able to identify and correct errors and for statistical purposes. This data is regularly deleted after a few days.

The legal basis for this data processing is the legitimate interest of the Controller in the above-mentioned purposes.

The website is hosted by a service provider on the basis of a data processing agreement. Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

3.2 Speed Kit

The website uses the tool Speed Kit, provided by Baqend GmbH, Stresemannstr. 23, 22769 Hamburg, Germany. The provider acts as a data processor on the basis of a data processing agreement.

Speed Kit is used to accelerate the delivery or display of the website in the browser of the website visitor.

As part of the use of Speed Kit, it is technically necessary for the accelerated delivery or display of the websites that the URL address called up (without personal components) and the IP addresses of the website visitors are transmitted to the provider of Speed Kit. The IP addresses are immediately anonymised and Speed Kit then only processes anonymous user or session IDs.

Speed Kit also uses cookies. These cookies are required for security purposes, in particular to detect bots and prevent DDoS attacks, and are also required to analyse the performance of Speed Kit and detect misconfigurations at an early stage. The storage period for cookies is six months.

Speed Kit does not create any personal profiles and no marketing or retargeting purposes are pursued. Speed Kit also uses a Content Delivery Network (CDN) as part of the acceleration process. A CDN accelerates the provision of website content by temporarily storing the content on numerous servers and transmitting it to the user from the server that is geographically closest to the user, thus enabling the content to be provided as quickly as possible.

The legal basis for this data processing is the Controller's legitimate interest in accelerating the delivery or display of the website and the associated optimization of the website experience of website visitors. If consent has been obtained, the expressly granted consent, which can be revoked at any time, constitutes the legal basis.

3.3 Content Delivery Network for the Website

The website uses a Content Delivery Network (CDN) to increase the security and delivery speed of the website. A CDN is a network of distributed servers that is able to deliver optimized content to users. For this purpose, personal data can be processed in server log files of the CDN provider.

Since a CDN is a network of servers that are often distributed worldwide, the use of a CDN may result in the transfer of personal data to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards upon request.

The legal basis for this data processing is the legitimate interest of the Controller in the above-mentioned purposes.

3.4 Cookies

Cookies are used on the website. Cookies are pieces of information that are transferred from our web server or third-party web servers to the browser of the website visitor and stored there for later retrieval. Cookies can be small files or other types of information storage. Information is stored in cookies that is generated in connection with the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that the identity of the website visitor can be obtained directly from a cookie.

When you visit the website, cookies are set that are absolutely necessary for the operation of the website. These absolutely necessary cookies may, for example, be cookies that are required to display the website with a content management system, that are used to recognize language settings or that are used to document whether consent has been given to the setting of further (optional) cookies or whether such storage has been rejected. The strictly necessary cookies, including their purpose and storage or deletion period, are explained below and also in the cookie banner that is displayed when the website is accessed.

Optional cookies are also used, for example, to collect additional information about the interests of visitors to the website or their usage behavior in order to analyze and optimize the website and customer interactions in general.

Optional cookies, including their purpose and storage or deletion period, are explained below and also in the banner that is displayed when the website is accessed. Optional cookies are only set if you have expressly consented to the setting of optional cookies.

Consent Management (CookieFirst)

Where legally required, the website uses the Consent Management Platform ("CMP") CookieFirst from the provider Digital Data Solutions B.V. in the Netherlands. The provider acts as a data processor on the basis of a data processing agreement.

CookieFirst is used to inform website visitors about the cookies used on the website and to request consent to the use of optional cookies and, if necessary, to document this.

When the website is accessed, the IP address and information about the browser and the end device used ("device fingerprint") are transmitted to the CookieFirst provider.

A permanent cookie may be stored in the browser to store the status of consent (which cookies have been consented to).

The legal basis for this data processing is initially the Controller's legitimate interest in obtaining the consent of website visitors to the storage of optional cookies as part of the provision of the website. If such consent has been given, the legal basis for the processing of the data for consent is the fulfillment of the legal obligation to obtain and document consent for this.

3.5 Videos (YouTube)

YouTube videos are embedded on the website. These are provided by Google Ireland Ltd. in Ireland via a plugin. The provider acts as a data processor on the basis of a data processing agreement.

When a website with the YouTube plugin is accessed, a connection to Google is inevitably established and the IP address of the website visitor is transmitted to Google.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

The legal basis for this data processing is the Controller's legitimate interest in the integration of videos and the associated optimization of the interactivity of the website and customer interactions.

3.6 Web Analytics (Google Analytics)

The website uses the web analytics service Google Analytics provided by Google Ireland Limited in Ireland. The provider acts as a data processor on the basis of a data processing agreement.

Google Analytics uses JavaScript tags to collect information about the use of the website. Google Analytics uses cookies to collect information on the interactions of visitors to the website with the website.

As part of the use of Google Analytics, the IP address of visitors to the website, information about the use of the website, browser type and version, operating system used, the previously visited page and the time of the server request are transmitted to Google servers and processed there.

The IP addresses of users collected are truncated within the EU before being transmitted to the USA. Only in exceptional cases, in the event of technical faults in Europe, will the unabridged IP address be transmitted to Google in the USA and abbreviated there. The transmitted IP addresses are not merged with other Google data.

Accordingly, personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

The legal basis for this data processing is the express consent of the website visitor.

3.7 Web Analytics (PostHog)

The website uses the web analytics service PostHog provided by PostHog, Inc., 2261 Market St. #4008, San Francisco, CA 94114, USA. We use the EU Cloud of PostHog, in which the data is processed exclusively on servers located in Frankfurt am Main, Germany. The provider acts as a data processor on the basis of a data processing agreement, which includes the EU Standard Contractual Clauses to safeguard any access to the data from the USA.

The use of the website is statistically analyzed in order to better understand how visitors use the website and to be able to continuously improve the website and the content and services offered. The data collected is used to create aggregated usage reports.

When using the web analytics service PostHog, the following data is processed:

• IP address of the user's accessing system (used only to calculate the hash value described below; not stored),
• the website accessed and the subpages accessed
• the website from which the user accessed the website (referrer)
• the time spent on the website,
• the number of visits to the website within one day,
• the browser and operating system used

PostHog is used in so-called cookieless mode. In this mode, PostHog does not set any cookies and does not store any data in the local storage or session storage of the browser; no information is stored on or read from the user’s end device. Instead of a persistent identifier, a hash value is calculated on the server side from the IP address of the user, the browser information (user agent), the domain accessed and a random salt value that changes daily. The IP address itself is not stored by PostHog.

As the salt value changes every day and is subsequently deleted, the hash value cannot be traced back to an individual user and a website visitor can only be recognised as a unique visitor within the same day. The data collected is only analysed in aggregated form.

The legal basis for this data processing is the Controller's legitimate interest in analysing the use of the website by its visitors and the continuous improvement of both the content and technical aspects of the website in accordance with the specific interests of visitors.

3.8 HubSpot

The website uses the service HubSpot, provided by HubSpot, Inc. in the USA. HubSpot is an integrated online marketing service from which various aspects of performance are utilized and deployed. Specifically, this involves email marketing (see below), chat and ticketing (see below), contact management (in particular user segmentation & CRM), landing pages and contact forms and recording and analyzing the origin of traffic and individual website visits.

HubSpot uses cookies to store and analyze the personal data of website visitors, in particular the user's activity, in particular which websites were visited and which elements were clicked on, as well as the IP address and device and browser information.

If, as shown below, an email newsletter has been subscribed to or a white paper has been downloaded or a website performance test has been carried out, HubSpot can be used to link the visits of a website visitor with the personal details (name/email address) in order to be able to inform website visitors individually and in a targeted manner about relevant topics.

The legal basis for this data processing is the express consent of the website visitors, which can be revoked at any time.

3.9 Cloudflare Turnstile

We use Cloudflare Turnstile, provided by Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA, to protect our website forms against spam and automated abuse. Turnstile checks whether a request is likely to originate from a human visitor. A successful check is required to submit a protected form.

For this check, your browser connects to Cloudflare and transmits technical signals, including your IP address, browser information (User-Agent), characteristics of the encrypted connection (TLS fingerprint), and the identifier of our Turnstile widget and associated website origin. Our server also sends the verification token and, where available, your IP address to Cloudflare to validate the check. We do not send the contents of your form fields to Turnstile.

The legal basis for our use of Turnstile is Art. 6 (1) lit. f) GDPR. Our legitimate interest is protecting our forms and systems against automated abuse and ensuring that we can reliably receive and process genuine inquiries.

Cloudflare acts as a data processor when processing these signals to protect our website. Cloudflare also uses the signals to improve its bot detection capabilities; for that purpose, Cloudflare acts as a separate controller and relies on its own legitimate interests, as explained in its Turnstile Privacy Addendum.

Data may be processed outside the EU/EEA, including in the USA. According to Cloudflare, transfers to the USA rely on its certification under the EU-U.S. Data Privacy Framework. Cloudflare provides EU Standard Contractual Clauses for transfers requiring these safeguards. Further information is available in the Cloudflare Data Processing Addendum and its Privacy Policy linked below.

According to its Privacy Policy, Cloudflare determines retention according to the purposes of processing, the nature and sensitivity of the data, the risks associated with its use or disclosure, and applicable legal obligations. Data is deleted or destroyed when the applicable retention period ends; where this is technically impossible, Cloudflare takes measures to prevent further use.

Further information about Cloudflare's processing and your data protection rights is available in the Turnstile Privacy Addendum and the Cloudflare Privacy Policy. For questions about our use of Turnstile or to exercise your rights, including your right to object on grounds relating to your particular situation, please contact us using the details in section 2.

4.1 Data Processor when Using Speed Kit

Speed Kit customers use Speed Kit to speed up the delivery and display of their websites in the website visitor's browser.

As part of the use of Speed Kit, it is technically necessary for the accelerated delivery or display of the websites that the URL address called up (without personal components) and the IP addresses of the website visitors are transmitted to us as the provider of Speed Kit. The IP addresses are immediately anonymized and Speed Kit then only processes anonymous user or session IDs. Speed Kit also uses cookies. These cookies are required for security purposes, in particular to detect bots and to prevent DDoS attacks and are also required to analyze the performance of Speed Kit and to detect misconfigurations at an early stage. The storage period for cookies is six months.

Speed Kit does not create any personal profiles and no marketing or retargeting purposes are pursued. Speed Kit also uses a Content Delivery Network (CDN) as part of the acceleration process. A CDN accelerates the provision of website content by temporarily storing the content on numerous servers and transmitting it to the user from the server that is geographically closest to the user, thus enabling the content to be provided as quickly as possible.

As the provider of Speed Kit, we act as a data processor on the basis of a data processing agreement when providing Speed Kit to customers.

4.2 Controller when Using Speed Kit

4.2.1 Creating an Account

If users set up or have an account set up for the use of the Speed Kit Dashboard or register as an invited user, Baqend processes the data of the users as Controller in order to enable them to use the Speed Kit Dashboard. This involves processing the user's surname and first name, address(es), contact data (e.g. email address, telephone number), contract data (e.g. subject matter of the contract, term), payment data and data required for the provision of the services.

The data is processed for as long as the respective account is used. If an account is closed/deleted, the data processed via the account will be deleted (subject to any retention obligations, see "Retention and deletion" below).

The legal basis for this storage and processing is the fulfillment of the contract and/or the Controller's legitimate interest in providing the application/platform and checking compliance with the terms of use.

4.2.2 Usage Analysis

In order to better understand how users use the Speed Kit Dashboard and to continuously improve the Speed Kit Dashboard and the services offered by Baqend, Baqend collects and analyzes the use of the Speed Kit Dashboard by users. The data processed is used to create aggregated/anonymized usage reports.

Web Analytics (PostHog)

For product analytics relating to the Speed Kit dashboard, Baqend uses the analytics tool “PostHog”. PostHog is a product analytics service operated by PostHog, Inc. (USA). Baqend uses PostHog Cloud EU, in which the data is processed on servers located in Frankfurt am Main, Germany. The provider acts as a data processor on the basis of a data processing agreement. PostHog is used exclusively to analyse the use of the Speed Kit dashboard; it is not used for advertising or retargeting purposes outside of the dashboard.

In this context, the following categories of data may in particular be processed:

• pages and functions accessed within the dashboard,
• timestamps, session duration and frequency of use,
• technical data relating to the end device and browser used,
• internal, pseudonymised user and/or account IDs (e.g. the user account in the Speed Kit dashboard).

Whether and how PostHog stores information on the user’s end device depends on the choice made by the user in the cookie banner of the Speed Kit dashboard:

If the user has consented to optional cookies, PostHog uses cookies and similar technologies (e.g. local storage) to recognise users across sessions and to assign events to sessions.

If the user has not (yet) consented or has rejected optional cookies, PostHog is used in so-called cookieless mode. In this mode, PostHog does not set any cookies and does not store any data in the local storage or session storage of the browser. Instead of a persistent identifier, a hash value is calculated on the server side from the IP address of the user, the browser information (user agent), the domain accessed and a random salt value that changes daily and is subsequently deleted. This hash value cannot be traced back to an individual user, and a user can only be recognised within the same day. The IP address itself is not stored.

The legal basis for the use of cookies and similar technologies and for the associated processing of data is the consent of the users of the Speed Kit dashboard, which is requested via the cookie banner of the dashboard; use of the dashboard is also possible without this consent. Consent can be withdrawn at any time with effect for the future, for example via the cookie settings in the dashboard or by contacting Baqend using the contact details provided above.

The legal basis for the analysis in cookieless mode, which does not involve the storage of or access to information on the user’s end device, is the Controller’s legitimate interest in analysing the use of the Speed Kit dashboard by its users and in the continuous improvement of the dashboard and the services offered.

Where data is transferred to countries outside the EU/EEA (in particular the USA), Baqend ensures an adequate level of data protection by implementing appropriate safeguards (such as EU Standard Contractual Clauses). Further information is available at: https://posthog.com/privacy.

Session replay

Where users have given separate consent, the session replay function of PostHog may also be used. In this case, individual usage sessions within the dashboard are recorded in the form of screen and interaction sequences in order to better trace errors and handle support requests more efficiently. Areas that may contain sensitive content are, where technically possible, masked or excluded from recording.

The legal basis is the separate consent, which can be withdrawn at any time with effect for the future (e.g. via the settings in the user account).

Heatmap (Hotjar)

The Hotjar web analysis service from the provider Hotjar Ltd. in Malta is used to analyze usage within the Speed Kit dashboard. The provider acts as a data processor on the basis of a data processing agreement.

Hotjar enables an analysis of the use of the Speed Kit dashboard by using cookies and a script to collect and process data on the use of the Speed Kit dashboard and on the behavior of users and the end devices used (in particular the IP address of the end device (in anonymized form), screen size, device type (unique device identifiers), information about the browser used, location (country only), preferred language). Hotjar stores this information in a pseudonymized user profile. The information is not used by Hotjar or Baqend to identify individual users or merged with other data about individual users. The data collected can be used to analyze user interactions with the Speed Kit dashboard, for example by creating heat maps.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

The legal basis for this data processing is the express consent of the users of the Speed Kit dashboard, which can be revoked at any time.

4.2.3 Chat Function and Ticketing

When creating support tickets and during live chat, the contact details and other content you provide will be processed. This processing is carried out to manage and process your support request.

An external service provider is used as a data processor for the ticketing system and live chat on the basis of a data processing agreement.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. Proof of these appropriate safeguards will be provided on request.

The legal basis for this storage and processing is the fulfillment of the contract and/or the Controller's legitimate interest in communicating with users of the application/platform and the efficient processing of support requests.

4.2.4 Transactional Messages

For the sending of transactional messages by email in connection with the use of the application/platform, an external service provider is used as a data processor who carries out the email dispatch and ensures the deliverability of the emails.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. Proof of these appropriate safeguards will be provided on request.

The legal basis for this processing is the performance of the contract and/or the Controller's legitimate interest in communicating with users of the application/platform.

4.3 Speed Kit Web Extension (Chrome extension)

The use of Speed Kit can be supplemented by an optional browser extension for Google Chrome (“Speed Kit Web extension” or “Chrome extension”). The use of the browser extension is voluntary and not required in order to use Speed Kit. The browser extension can be installed, activated, deactivated and uninstalled at any time via the browser settings.

The browser extension is used in particular to facilitate the use of Speed Kit in the browser and to enable technical errors to be reported more quickly and in a more traceable manner in order to improve the stability and performance of the services offered.

4.3.1 Data processed when using the browser extension

Depending on the configuration of the browser extension (“active”/“inactive”) and depending on whether an error is recorded automatically or an error report is triggered by the user, in particular the following data may be processed and logged in a debug or error analysis tool:

• Technical identification and usage data (e.g. Speed Kit specific cookies or similar identifiers, URL of the page accessed, time of the event (timestamp), where applicable browser and device data such as browser type/version and operating system),
• Debug and performance data (e.g. DOM snapshot / HTML structure of the affected page at the time of the error, resource timings such as loading times and performance data for the page and its resources, console logs including error and warning messages),
• Visual content (e.g. full page screenshot of the affected page (“full page screenshot”) as well as – if selected by the user – additional screenshots or other content transmitted as part of an error report).

In individual cases, this data may contain personal information, for example where personal content is displayed in the visible area of the page (e.g. names, contact details, individual content of a user account) or where such information is contained in the URL or HTML structure. Where the extension provides free-text fields or upload functions, the information voluntarily entered or uploaded by the user may also contain personal data.

4.3.2 Manner of data collection

Data may in particular be collected in the following ways:

• Automatic debugging when the browser extension is active: If the browser extension is active, the above-mentioned technical debug information may be collected automatically in the event of certain technical errors and transmitted to the debug or error analysis tool.
• User-initiated error reports: Users can actively trigger error reports via the browser extension. In this case, depending on the configuration, additional free-text information and selected screenshots or other content may be transmitted to the debug or error analysis tool.

Users can configure the browser extension and – where technically provided – individual functions (e.g. automatic error reporting) at any time in the extension settings.

4.3.3 Purposes of processing

The processing of data collected via the browser extension serves in particular the following purposes:

• detection, analysis and correction of technical errors (debugging),
• ensuring and improving the stability, performance and security of the Speed Kit services,
• supporting customer support in handling enquiries and error reports,
• further development and optimisation of the products and services offered.

The data collected via the browser extension is not used for marketing, advertising or retargeting purposes.

4.3.4 Legal bases for processing

The legal basis for the processing of data collected via the browser extension is generally the legitimate interest of the Controller in detecting, analysing and correcting technical errors, ensuring the security and stability of the services and efficiently handling support requests.

Where users voluntarily provide additional information in the browser extension (e.g. free-text information, additional screenshots or optional debug data) or actively enable certain optional functions (e.g. automatic error reporting, where implemented as an opt-in), the processing of such data is additionally based on the express consent of the users. Any consent given can be withdrawn at any time with effect for the future, for example by deactivating the relevant function in the browser extension or by uninstalling the extension.

Where data in connection with the browser extension is processed for the performance of contractual obligations (e.g. for the provision of the contractually agreed services to customers), the performance of a contract or the taking of steps prior to entering into a contract may additionally serve as a legal basis.

4.3.5 Recipients and international data transfers

Within Baqend, only those departments have access to the data collected via the browser extension that require this data for the purposes described above (e.g. development, IT, support).

External service providers may be used as processors for the storage and analysis of debug and log data (e.g. hosting providers, log management and monitoring services, providers of error tracking or crash reporting solutions). These service providers process personal data exclusively on the basis of a data processing agreement and in accordance with the Controller’s instructions.

Insofar as personal data is transferred to recipients in third countries (outside the EU/EEA) in connection with the use of the browser extension, the explanations on data transfers to third countries contained in this Privacy Policy apply accordingly. Appropriate safeguards within the meaning of Art. 44 et seq. GDPR are ensured.

4.3.6 Storage period and erasure

Personal data collected via the browser extension is stored only for as long as is necessary for the purposes described above.

In particular, detailed debug and log data (e.g. URL, timestamp, DOM snapshot, resource timings, console logs, screenshots) is generally deleted or anonymised after no more than [e.g. 30 / 90 days], unless a longer retention period is required in an individual case (e.g. to clarify specific incidents or to establish, exercise or defend legal claims). Configuration data of the browser extension (e.g. information on whether certain functions are enabled or disabled) is generally stored for as long as the browser extension is installed or until settings are reset or the extension is uninstalled.

4.4 Speed Kit Insights

In addition, we offer a module called “Speed Kit Insights”, which uses AI-based methods to analyse the usage and performance data processed in the context of Speed Kit (real user monitoring). Speed Kit Insights only accesses these RUM data already processed by us on behalf of our customers and does not collect any additional categories of data. In the Insights layer, no IP addresses are processed in plain text; only pseudonymised identifiers and aggregated metrics are used.

Processing takes place in data centres within the European Union (including Google Cloud Platform, region Eemshaven, Netherlands). Our role as processor and the purposes of processing (technical analysis and optimisation of the performance of our customers’ websites) remain unchanged; details are set out in the respective data processing agreements concluded with our customers.

4.5 Use of aggregated Speed Kit data for product improvement

In addition to providing Speed Kit and Speed Kit Insights to our customers, Baqend uses anonymised and/or aggregated technical data derived from their operation (for example general performance indicators, error statistics and usage patterns) to analyse and improve its own products and services. These analyses do not relate to identified or identifiable individuals and do not allow any conclusions to be drawn about individual website visitors or end users.

When chatting on the website or as part of the platform, when making support requests or creating support tickets and when processing requests, the personal data provided, the user's contact details and the other content and information provided are collected and processed in order to manage, process and document the respective request. In addition, information about the browser, the IP address and the location of the respective user is processed.

An external service provider is used as a data processor for the chat and the ticketing system.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

The legal basis for this storage and processing is the performance of the contract or the implementation of pre-contractual measures and/or the Controller's legitimate interest in the provision of services and communication with the users of the website or platform and the provision of optimal support for the users of the platform or visitors to the website.

If you contact us, e.g. by email, via a contact form or via a live chat, the information you provide will be processed for the purpose of handling your inquiry.

We need the information requested in a contact form or live chat in order to process your inquiry, address you correctly and send you an answer.

We process the data of our customers, service providers and suppliers as part of the provision of our contractual services. This may involve processing inventory data (e.g. surname and first name of the contact person(s), address), contact data (e.g. email address, telephone number), contract data (e.g. subject matter of the contract, term), payment data and data that is collected as part of the provision of services and/or is necessary for the provision of services.

Inquiries and customer relationships are regularly processed in our CRM system. The data processed (surname, first name, title, postal address, date of birth if applicable, your specific interest in our products and services and your interactions with us) may also be used by us for direct marketing purposes, in particular for postal advertising, in compliance with legal requirements.

The legal basis for this data processing is the Controller's legitimate interest in communicating with customers, service providers, suppliers, interested parties, visitors to the website and other third parties, in maintaining relationships with interested parties, customers and service providers and in marketing the products and services. If the contact is aimed at the conclusion of a contract or takes place in the context of the performance of a contract, the legal basis for the processing is the fulfillment of the contract or the implementation of pre-contractual measures.

To support employees in their daily work and improve the quality and consistency of communication, the Controller uses AI applications, including ChatGPT from OpenAI, Microsoft Copilot, Google Gemini for Workspace, and Claude from Anthropic. These applications are particularly helpful in drafting or summarizing emails and documents.

The use of AI is strictly limited to internal productivity purposes, such as helping employees prepare responses or extracting relevant content from previous communications. The AI applications used only have access to content that employees themselves can access. Decisions are never made solely by AI; all results and suggestions are always reviewed by employees before being shared externally.

We ensure, through contractual agreements with the AI providers as well as through technical configurations (e.g. the use of enterprise versions or closed API interfaces), that personal data entered into the AI systems is not used by the providers for training or improving their own base models. Data sovereignty remains fully with us.

AI is used on the basis of the Controller's legitimate interest, as this support enables employees to respond more efficiently and effectively to inquiries and communications. Careful consideration has been given to ensuring that the interests and fundamental rights of the data subjects are not affected by this use. This is ensured in particular by the fact that the use of AI is clearly defined, strictly limited, and always subject to human control. In addition, the Controller implements comprehensive internal security measures, including clear internal guidelines on the use of AI, regular employee training, and appropriate data protection controls. This ensures that processing is fair, proportionate, and respectful of privacy.

8.1 Registration

You can register on the website to receive an email newsletter. When you register, the data from the input screen, the IP address of the accessing computer and the date and time of registration are collected and stored.

The so-called "double opt-in" procedure is used to verify that a registration for the sending of a newsletter is made by the actual owner of an email address. In this process, a confirmation email is sent to the registered email address after an email address has been registered. Registration for the newsletter is only completed when a confirmation link contained in the confirmation email is activated. The IP address of the accessing computer and the date and time of activation of the confirmation link are also collected and stored.

You can unsubscribe from the newsletter at any time by using the unsubscribe link contained in each newsletter or by contacting the Controller using the contact details provided above.

The legal basis for the processing of data as part of the registration and sending of the email newsletter is your express consent, which can be revoked at any time.

Please note that if consent is withdrawn, the consent data will be stored until the statutory limitation period expires to enable the Controller to defend itself legally if necessary. The duty of accountability and proof takes precedence over the duty of erasure for this period. The legal basis for this retention of consent data is the fulfillment of a legal obligation (accountability) and the Controller's legitimate interest in a potential legal defense.

8.2 Email Newsletter for Existing Customers

If you register as a user of the platform and enter your email address, it may be used to send you an email newsletter, provided you have not objected to such use. Only direct advertising for our own similar goods or services is sent via the email newsletter as part of an existing customer relationship. You can object to the use of your email address for this purpose at any time, without incurring any costs other than the transmission costs according to the basic rates, by using the unsubscribe link contained in each email newsletter or by contacting the Controller using the contact details given above.

The legal basis for sending the email newsletter as part of an existing customer relationship is the Controller's legitimate interest in carrying out direct marketing measures.

Please note that in the event of an objection to the further sending of the email newsletter as part of an existing customer relationship, the consent data will be retained until the expiry of the statutory limitation period in order to enable the Controller to defend itself legally if necessary. The obligation to provide accountability and evidence takes precedence over the obligation to delete data for this period. The legal basis for this retention of consent data is the fulfillment of a legal obligation (accountability) and the Controller's legitimate interest in a potential legal defense.

8.3 Newsletter Analytics/Tracking

A statistical analysis of usage data can be carried out for the email newsletter. For this purpose, the openings of the email and the internal clicks are collected and stored. This information is used to measure and optimize the success of the email newsletter campaigns by making the content of the email newsletters more interesting and relevant for the target group.

The legal basis for this analysis is the consent expressly granted and revocable at any time.

8.4 Newsletter Service Provider

An external service provider is used as a data processor to send and analyze the email newsletter.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

9.1 Social Media Buttons

Social media buttons of various social media networks (e.g. LinkedIn, Instagram, X and Facebook) are integrated on our website.

If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account with the social media network.

For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policy of the providers of the social media networks. The legal basis for the integration and use of social media buttons is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our offers and our website.

9.2 Social Media Pages

We maintain a publicly accessible profile on various social media networks (e.g. LinkedIn, Instagram, X and Facebook).

If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account with the social media network and enrich it there. Even if you are not logged in or if you do not have an account with the respective social media network, personal data may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.

The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.

If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal data that takes place there. For information on the collection and processing of your personal data that takes place there, we refer you to the privacy policy of the respective social media network.

You can assert your data subject rights in accordance with Chapter III. of the GDPR (right to information, correction, deletion, restriction of processing, data portability, etc.) both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal data and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider.

The legal basis for our use of social media pages is our legitimate interest in the presence and marketing of our products and services on the Internet.

When participating in an online meeting or a webinar offered or conducted by the Controller, the personal data of the participants is processed.

When participating in an online meeting or webinar, various categories of data are processed. The scope of the data also depends on what data the participants provide about themselves and as part of their participation.

When participating in an online meeting or a webinar, at least a name must regularly be provided when registering. However, a pseudonym can also be used. The IP address of the participants is also processed to enable participation. Login information and device/hardware information is also processed. Furthermore, if specified, the participant's email address and profile picture will be processed. In the case of participation by telephone, the telephone number and, if applicable, the IP address are processed, if transmitted.

When participating in an online meeting or a webinar, if the participant has activated the microphone and/or a camera on the end device, the participant's image and sound data will be processed as part of the participation. If the screen is shared, the information from this screen share is also processed. Participants are free to activate the microphone, camera or screen share.

Audio and video recordings of online meetings or webinars can be created. In this case, the data of all audio, video and presentation recordings will be processed. There will always be a reference to the recording if one is made and, if necessary, the explicit consent of the participants will always be obtained for the recording.

It is also possible to use the chat, question or survey functions in online meetings or webinars. In this respect, the text entries made by the participants are processed in order to display them in the respective online meeting or webinar and, if necessary, to record them.

An external service provider is used as a data processor to conduct and, if necessary, record online meetings and webinars.

Personal data may be transferred to third countries that do not offer an adequate level of data protection. In this case, it is ensured that appropriate safeguards are provided for such a transfer in order to ensure an adequate level of data protection. The Controller will provide evidence of these appropriate safeguards on request.

The legal basis for this processing is the fulfillment of the contract or the implementation of pre-contractual measures, provided that the implementation and participation in the online meeting or webinar within the framework of an existing contractual relationship is necessary for the fulfillment of the contract or is aimed at the conclusion of a contract. This is regularly the case for employees, customers, interested parties, service providers and suppliers. Otherwise, the legal basis for processing is the Controller's legitimate interest in efficient communication, both internally and with external stakeholders.

11.1 Active Sourcing

We carry out so-called active sourcing measures to identify promising potential employees on the external labor market and actively contact potential applicants and employees. The purpose of data processing is recruitment, e.g. by individually drawing the attention of promising candidates to job vacancies in our company.

We collect the following categories of data for active sourcing: surname, first name, gender, contact details, education, professional experience, qualifications, salary data, application data, non-professional experience and interests and other information resulting from public profiles on social networks, in particular LinkedIn and Xing, and/or from other publicly accessible sources on the internet.

All personal data processed in the context of active sourcing is collected from generally/publicly accessible sources on the Internet, in particular from social networks such as LinkedIn and Xing.

The legal basis for the collection and processing of publicly accessible data in the context of active sourcing is the Controller's legitimate interest in identifying, approaching and recruiting the best possible employees for the company.

11.2 Application Process

We collect and process personal data from applicants for the purpose of carrying out the application process.

When we conclude an employment contract with an applicant, the data provided will be processed for the purpose of implementing the employment relationship in accordance with the statutory provisions. If no employment contract is concluded, the application documents will be deleted immediately, at the latest 6 months after the end of the application process, provided that there is no overriding legitimate interest, such as the defense against claims or a function of preserving evidence in accordance with equal treatment and anti-discrimination laws.

The legal basis for this storage and processing is the implementation of pre-contractual measures (decision on the establishment of an employment relationship). If the data is required for legal defense or prosecution after the application process has been completed, data processing may be carried out to protect legitimate interests. In this case, our legitimate interests consist of defending against legal claims or asserting legal claims.

11.3 Internet Research as Part of the Application Process

As part of the application process, publicly available information about applicants may be viewed on the Internet. This includes, in particular, professional profiles on social networks (e.g., LinkedIn), publicly accessible profiles on other social media, and information from generally accessible sources (e.g., press articles, blogs, websites, search engine results).

Only publicly available information about the applicant will be processed. There is no systematic or automated decision-making or profiling.

The Internet search serves to supplement the application documents in order to better assess the professional suitability, career history, qualifications, and public professional presence of the applicants. This provides a sound basis for selecting suitable candidates.

The legal basis for this processing is the legitimate interest of the potential future employer in a comprehensive and well-founded assessment of the suitability of applicants for the advertised position.

11.4 Background Checks

As part of the application process, it may be necessary to carry out additional checks ("background checks"), particularly for security-related positions, management roles, activities involving financial responsibility, or access to confidential company information. These checks serve to verify the information provided in the application process and to assess the professional integrity, reliability, and suitability of the applicant for the respective position.

Depending on the type of position advertised and the requirements, information on education, professional career, qualifications, references, and, if applicable, creditworthiness information or information from public registers may be collected and processed in the course of such background checks. If the advertised position requires it or if legal requirements demand it (e.g., for activities in sensitive compliance, finance, or IT areas), the submission of an official certificate of good conduct may also be required in individual cases. In this case, processing is carried out exclusively on the basis of the documents voluntarily submitted by the applicant; we do not carry out any automated queries.

To carry out background checks, external service providers may be commissioned as processors to assist us in verifying qualifications or obtaining references, if necessary. In addition, in individual cases, previous employers, references, or educational institutions may be contacted, provided that the applicant has given their express prior consent.

The legal basis for the processing of personal data in the context of background checks is primarily the implementation of pre-contractual measures (decision on the establishment of an employment relationship), insofar as the check is necessary for the decision on the establishment of an employment relationship. The legal basis for these checks is their necessity for the employment relationship in conjunction with any applicable legal requirements. To the extent that checks go beyond this (e.g. reference checks with former employers), they are carried out exclusively on the basis of your express consent.

Before a background check is carried out, the applicant is always informed transparently about the nature, scope, and purpose of the planned check. If consent is required for certain checks, this is obtained separately in advance. Personal data will not be processed or passed on beyond the stated purpose.

11.5 Use of Automated (AI) Processes

As part of our application process, we use partially automated processes to preselect applications. The application documents submitted (e.g., resume, qualifications, professional experience) are analyzed using an AI-supported system according to specific, predefined criteria. The aim is to identify applications that are particularly well suited to the requirements of the advertised position.

The automated evaluation is used exclusively to support our HR managers. The final decision on the continuation of the application process is not made automatically, but always by a natural person.

The system used evaluates application documents based on predefined criteria (e.g., education, professional experience, language skills, qualifications). On this basis, a preliminary classification or weighting is carried out, which serves as a guide for the subsequent manual review.

This evaluation has no legal effect and does not have any comparable significant impairment.

Every applicant has the right to request a human review of the automated pre-selection, to present their point of view, and to challenge the decision.

11.6 Compliance/Sanctions Screening

Applicants who are shortlisted as part of the application process may be subject to an initial compliance check. The compliance check involves a comparison of the applicant's name and address with relevant sanctions lists, in particular on the basis of the EU anti-terrorism regulations.

To carry out the compliance/sanctions list screening, we use an external service provider as a data processor on the basis of a data processing agreement.

The legal basis for this storage and processing is, if there is a legal obligation to carry out a compliance/sanctions list screening, the fulfillment of the legal obligation. In individual cases, depending on a balancing of interests, compliance/sanctions list screening can also take place if there is no mandatory legal obligation. In this case, the legal basis is our legitimate interest in avoiding potential sanctions by foreign authorities.

11.7 Talent Pool

If an applicant submits an unsolicited/speculative application without reference to a specific job posting, expressing general interest in potential future employment opportunities, or if an applicant has consented to the longer retention of their data in our talent pool in the context of an application process for a specific position, we will store the data submitted as part of the application in our talent pool for a period of 2 years after receipt of the unsolicited/speculative application or after the conclusion of the application process. This storage serves the purpose of identifying potentially suitable future positions for the applicant and contacting them if applicable. After this period, the data will be deleted.

Such consent to the storage of application data in our talent pool can be withdrawn at any time for the future. To do so, please send us an email to the contact details provided above.

The legal basis for the storage of application documents in our Talent Pool is, where applicable, the explicit consent of the applicant, which can be revoked at any time.

11.8 Statistical evaluations

We process anonymized or aggregated application data in order to analyze and improve our recruiting process (e.g., to evaluate application numbers, sources, or success rates). These evaluations are carried out using anonymized/aggregated data without personal references.

Some of our production sites are monitored by video. This monitoring is clearly indicated by signs. The legal basis for this storage and processing is Art. 6 (1) lit. b) GDPR. The purpose of video surveillance and our legitimate interest is to safeguard the rights of the home, to protect our employees from dangerous situations, to protect our property, in particular our business premises including equipment, and to preserve evidence after criminal offences. Only the management has access to the records. In individual cases, the records may be passed on to criminal prosecution authorities in accordance with their purpose. The deletion of the data is carried out by the system after 7 working days, provided that there are no incidents in the sense of our legitimate interest, which make a longer storage necessary.

If we are involved in a restructuring, acquisition, asset sale, merger, financing, transfer of services to another provider, due diligence, insolvency or receivership, your personal data may be transferred to third parties to the extent legally permitted in connection with and as part of the relevant legal process, subject to the basic principles of data protection law.

This website is not intended or designed for use by children under the age of 16. We do not knowingly collect personally identifiable information from or about anyone under the age of 16.

Within the Controller's organization, access to data is granted to those internal departments or organizational units that need it to perform their tasks, if necessary to fulfill contracts, for data processing based on the consent of the data subject(s) or to protect overriding legitimate interests.

Data will only be passed on to third parties in accordance with legal requirements. Your data will only be passed on to third parties if this is necessary for contractual purposes or to safeguard our overriding legitimate interest in the effective performance of our business operations.

If we use service providers or third-party providers to provide the website or other services, we take suitable legal precautions and appropriate technical and organizational measures to ensure the protection of your personal data.

Within the scope of the legal requirements, data subjects have the following rights with regard to the processing of personal data:

16.1 Right of Access

Data subjects have the right to request information about the personal data processed about them.

16.2 Right to Rectification

Data subjects have the right to request the rectification of inaccurate personal data concerning them. They also have the right to request the completion of incomplete personal data.

16.3 Right to Erasure

Data subjects have the right to request the erasure of personal data concerning them.

16.4 Right to Restriction of Processing

Data subjects have the right to request that the processing of personal data concerning them be restricted.

16.5 Right to Object to Processing

Data subjects have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or which is based on a legitimate interest. In this case, the data will no longer be processed unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

In addition, data subjects have the right to object at any time to the processing of personal data concerning them for the purpose of direct marketing; this also applies to any profiling insofar as it is associated with such direct marketing.

16.6 Right to Withdraw a Consent

Data subjects have the right to withdraw their consent if they have given their consent for processing.

16.7 Right to Data Portability

Data subjects have the right to receive the personal data concerning them, which they have provided to a Controller, in a structured, commonly used and machine-readable format ("data portability") and the right to transmit those data to another Controller.

16.8 Exercising the Rights

The rights of data subjects can be exercised by notifying the Controller or, where applicable, the Data Protection Officer using the contact details provided above.

16.9 Right to Lodge a Complaint with the Data Protection Supervisory Authorities

If data subjects believe that the processing of personal data concerning them breaches data protection law, they have the right to lodge a complaint with a data protection supervisory authority.

The provision of personal data is neither legally nor contractually required. There is no obligation to provide personal data, however, the provision of personal information is necessary for the conclusion of a contract insofar as certain information is mandatory in order to conclude (and execute) a contract.

Automated decision-making, including profiling, is not carried out.

We adhere to the principles of data avoidance and data economy and only store your personal data for as long as is necessary to achieve the respective purpose of the data processing purposes or as stipulated by the storage periods provided by law.

If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely anonymized or deleted in accordance with the statutory provisions.

We take appropriate technical and organizational measures in accordance with the state of the art to ensure a level of protection for the personal data we process that is appropriate to the risk of the respective processing and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, inquiries or payment data that you send to us.

Our employees receive regular training on data protection and information security and are committed to confidentiality and data protection.

A restrictive rights and roles concept on a "need to know" basis ensures that employees only have access to the personal data they absolutely need to perform their duties.

We reserve the right to amend this Privacy Policy from time to time so that it always complies with current legal requirements and/or in order to implement changes to our services in the Privacy Policy, e.g. when introducing new services. When visiting the website or using our services, the current privacy policy always applies.