Privacy Policy

Preamble

With the following privacy policy, we want to inform you about the types of your personal data (hereinafter also briefly 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 within the scope of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").

The terms used are not gender-specific.

Status: April 18, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Operations
• Relevant Legal Bases
• Security Measures
• Transfer of Personal Data
• International Data Transfers
• General Information on Data Retention and Deletion
• Rights of Data Subjects
• Business Services
• Payment Procedures
• Provision of the Online Offering and Web Hosting
• Use of Cookies
• Contact and Inquiry Management
• Promotional Communication via Email, Post, Fax, or Telephone
• Online Marketing
• Presences in Social Networks (Social Media)
• Changes and Updates
• Definitions

Controller

Louis-Morris Ried
Neckarstraße 1, 74354 Besigheim, Germany

Email address: hallo@latelio.de

Phone: 004915116108002

Overview of Processing Operations

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

Types of Processed Data

• Inventory data.
  
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Metadata, communication, and procedural data.
• Log data.

Categories of Data Subjects

• Service recipients and clients.
  
• Prospects.
• Communication partners.
• Users.
• Business and contractual partners.
• Third parties.
• Whistleblowers.

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Direct marketing.
• Reach measurement.
• Tracking.
• Office and organizational procedures.
• Target group formation.
• Organizational and administrative procedures.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Whistleblower protection.
• Public relations.
• Sales promotion.
• Business processes and commercial procedures.

Relevant Legal Bases

Relevant Legal Bases under the GDPR: Below, you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the GDPR regulations, national data protection provisions in your or our country of residence or establishment may apply. Furthermore, if more specific legal bases are relevant 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 consent to the processing of his or her personal data for one or more specific purposes.
• Performance of a contract and pre-contractual requests (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) - 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 Germany: In addition to the data protection regulations of the GDPR, national data protection regulations in Germany apply. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special provisions regarding 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 transfer as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

In accordance with statutory requirements, and taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and separation thereof. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data, and responses to data breaches. We also consider the protection of personal data during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

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

Transfer of Personal Data

In the course of our processing of personal data, it may happen that data is transferred to other entities, companies, legally independent organizational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT functions, or providers of services and content embedded in a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

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

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. Additionally, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should there be any changes within the DPF, the standard contractual clauses will act as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of political or legal changes.

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

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

General Information on Data Retention and Deletion

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

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

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

If there are multiple indications of retention periods or deletion deadlines for a piece of data, the longest period is always decisive. Data that is no longer used for its originally intended purpose, but is retained due to legal requirements or other reasons, will only be processed for the reasons that justify its retention.

Retention and deletion of data: The following general deadlines apply to retention and archiving under German law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
• 8 years - Accounting records, such as invoices and expense receipts (§ 147 para. 1 nos. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
• 6 years - Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g., time sheets, cost accounting sheets, calculation documents, price markings, but also payroll records, insofar as they are not already accounting records, and cash register strips (§ 147 para. 1 nos. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
• 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, and to process related inquiries, based on previous business experiences and usual industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

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

Rights of Data Subjects

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

• Right to object: 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 Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to 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 given consents at any time.
• Right of access: You have the right to request confirmation as to whether personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal provisions.
• Right to rectification: In accordance with legal provisions, you have the right to demand the completion of incomplete personal data concerning you or the rectification of inaccurate personal data concerning you.
• Right to erasure and restriction of processing: In accordance with legal provisions, you have the right to demand the immediate erasure of personal data concerning you, or, alternatively, to demand the restriction of processing of the data in accordance with legal provisions.
• Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and to transmit those data to another controller in accordance with legal provisions.
• Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you 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.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, prospects, suppliers, and other cooperation partners (collectively "Contractual Partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

The processing serves, in particular, the fulfillment of our primary and secondary contractual obligations. This includes the provision of agreed services, any update and information obligations, the processing of warranty and other service disruptions, the handling of cancellations, terminations of continuing obligations, reversals, refunds, and the processing of other contract-related declarations and inquiries. This covers both one-time contracts and ongoing contractual relationships.

Specifically, master data such as name, address, and, if applicable, company name, contact data such as email address and telephone number, contract and service data such as contract subject, contract term, order or transaction number, usage and service data, payment and billing data, as well as communication content and histories are processed. Where necessary, we also process data that is disclosed or transmitted to us in the course of executing an order.

In addition, we process data to safeguard our rights and to fulfill legal obligations. This includes, in particular, commercial and tax law retention requirements, documentation requirements, and, if applicable, proof and accountability requirements. Furthermore, processing is carried out based on our legitimate interests in proper business management, internal administration, risk control, and IT security, as well as in protecting our business operations and our contractual partners from misuse, endangerment of data, secrets, and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the execution of the contract or to fulfill legal obligations.

Personal data is only passed on to third parties if this is necessary for the fulfillment of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests, or for the fulfillment of legal obligations. We will inform you separately about further processing, in particular for marketing purposes, within the framework of this data protection declaration.

We will inform the contractual partners which data is required in individual cases when collecting the data, for example, by appropriate labeling in online forms or during personal contact.

Data will be deleted as soon as it is no longer required for the aforementioned purposes and no legal retention obligations prevent deletion. Legal retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted within the scope of a specific order will be deleted after completion of the order and expiry of any retention periods, unless there are further legal or contractual obligations to store the data.

The legal basis for processing is Art. 6 Para. 1 lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 Para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it is carried out on the basis of Art. 6 Para. 1 lit. f GDPR. Insofar as processing is based on Art. 6 Para. 1 lit. f GDPR, it is carried out to protect our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and development of our business operations. These interests particularly consist in ensuring a secure and legally compliant business operation as well as in maintaining our entrepreneurial capacity to act.

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and e-mail addresses or telephone numbers); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, involved persons).
• Data subjects: Recipients of services and clients; prospects. Business and contractual partners.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and commercial procedures.
• Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
• Legal bases: Performance 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).

Further information on processing processes, procedures and services:

• Online shop, order forms, e-commerce and performance of services: We process the data of our customers to enable them to select, acquire, or order the chosen products, goods, and associated services, as well as their payment and provision, or delivery, or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding, and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers for the processing of payment transactions. The required information is identified as such within the order or comparable purchase process and includes the information required for delivery or provision and billing, as well as contact information to enable any consultation; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Payment procedures

Within the framework of contractual and other legal relationships, due to legal obligations, or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects and use other service providers in addition to banks and credit institutions (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorized access during transmission.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum 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 confirming or denying payment. In some circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and credit checks. We refer to the terms and conditions and the data protection notices of the payment service providers in this regard.

The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and for exercising rights of revocation, information, and other data subject rights.

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject matter of the contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, involved persons). Contact data (e.g., postal and e-mail addresses or telephone numbers).
• Data subjects: Recipients of services and clients; business and contractual partners. Prospects.
• Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and commercial procedures.
• Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
• Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
• Klarna: Payment services (technical integration of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
• Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy Policy: https://www.mastercard.de/de-de/datenschutz.html.
• PayPal: Payment services (technical integration of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
• Visa: Payment services (technical integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.

Provision of the online offering and web hosting

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, involved persons). Log data (e.g. log files concerning logins or the retrieval of data or access times).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Retention and deletion: Deletion according to the information in the "General information on data storage and deletion" section.
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

• Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and also to ensure server load and stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes are exempt from deletion until the final clarification of the respective incident.

Use of cookies

The term "cookies" refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as the functionality, security and comfort of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the user's consent in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential to be able to provide explicitly requested content and functions. This includes, for example, the storage of settings and the assurance of the functionality and security of our online offering. Consent can be revoked at any time. We clearly inform about their scope and which cookies are used.

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

Storage period: With regard to the storage period, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, user data collected with the help of cookies can be used for reach measurement. If we do not explicitly provide users with information on the type and storage duration of cookies (e.g. within the framework of obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their given consent at any time and also object to the processing in accordance with legal requirements, also via the privacy settings of their browser.

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

Further information on processing processes, procedures and services:

• Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named in the consent management solution. This procedure serves to obtain, log, manage, and revoke consent, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' end devices. Within the scope of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymized user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers) as well as information about the browser, the system, and the end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by mail, contact form, email, phone, or via social media) and within the scope of existing user and business relationships, the information of the inquiring persons is processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

• Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., text or image messages and posts as well as information relating to them, such as authorship details or time of creation). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion."
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further notes on processing processes, procedures, and services:

• Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to respond to and handle the respective request. This typically includes information such as name, contact information, and possibly further information provided to us and necessary for proper processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Advertising communication via email, mail, fax, or telephone

We process personal data for the purpose of advertising communication, which may take place via various channels, such as email, telephone, mail, or fax, in accordance with legal requirements.

Recipients have the right to revoke their granted consent at any time or to object to advertising communication at any time free of charge via the contact options mentioned above.

After revocation or objection, we store the data necessary to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the user's revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, name).

• Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., text or image messages and posts as well as information relating to them, such as authorship details or time of creation).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Direct marketing (e.g., by email or mail); Marketing. Sales promotion.
• Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion."
• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Online Marketing

We process personal data for the purpose of online marketing, which may include, in particular, the marketing of advertising space or the display of promotional and other content (collectively referred to as "content") based on potential user interests, as well as measuring their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the information relevant to the display of the aforementioned content is stored for the user. This 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 about usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) for user protection. Generally, no clear user data (such as email addresses or names) are stored within the scope of the online marketing procedure, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles.

The statements in the profiles are generally stored in the cookies or by similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, supplemented with further data, and stored on the server of the online marketing procedure provider.

In exceptional cases, it is possible to assign clear data to the profiles, primarily when users are, for example, members of a social network whose online marketing procedures we use and the network links the user profiles with the aforementioned information. Please note that users can make additional agreements with the providers, for example by giving consent during registration.

We generally only gain access to aggregated information about the success of our advertisements. However, within the framework 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 a contract with us. The conversion measurement is used solely for the success analysis of our marketing measures.

Unless otherwise stated, please 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 data processing is permission. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Notes on revocation and objection:

We refer to the privacy policies of the respective providers and the objection options (so-called "opt-out") provided for the providers. If no explicit opt-out option has been provided, it is possible, on the one hand, to disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore also recommend the following opt-out options, which are offered collectively for respective areas:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-regional: https://optout.aboutads.info.

• Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of recurring visitors); Tracking (e.g., interest/behavior-based profiling, use of cookies); Target group formation; Marketing. Profiles with user-related information (creation of user profiles).
• Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
• Security measures: IP masking (pseudonymization of the IP address).

Presences in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context to communicate with users active there or to offer information about us.

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.

Furthermore, user data within social networks are generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These may then be used to place advertisements inside and outside the networks that presumably correspond to the users' interests. Therefore, cookies are generally stored on users' computers, in which user behavior and interests are stored. In addition, data independent of the devices used by users can also be stored in the usage profiles (especially if they are members of the respective platforms and logged in there).

For a detailed description of the respective processing forms and objection options (opt-out), we refer to the privacy policies and information of the operators of the respective networks.

Even in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

• Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts as well as information relating to them, such as authorship details or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g., website visitors, users of online services).
• Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
• Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion."
• Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further notes on processing processes, procedures, and services:

• Instagram: Social network, enables sharing photos and videos, commenting on and liking posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes in 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 we ask you to check the information before contacting them.

Definitions of Terms

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

• Inventory Data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems, by enabling clear assignment and communication.
• Content Data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
• Contact Data: Contact data are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
• Meta, Communication, and Procedural Data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, includes information describing the context, origin, and structure of other data. It may include information about file size, creation date, the author of a document, and revision histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved persons, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used for tracing and reviewing operations.

Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data can also include frequency of use, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.

Personal Data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Profiles with User-Related Information: The processing of "profiles with user-related information", or "profiles" for short, comprises any type of automated processing of personal data consisting of the use of such personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (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.

Log Data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring, or to create performance reports.

Reach Measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify when users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.

Tracking: "Tracking" refers to the ability to follow the behavior of users across multiple online offerings. Typically, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.

Controller: A "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 virtually any handling of data, be it collection, evaluation, storage, transmission, or deletion.

Contract Data: Contract data refers to specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged, or sold. This data category is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include contract start and end dates, the type of services or products agreed upon, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.

Payment Data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is critical for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data can also include information about payment status, chargebacks, authorizations, and fees.

Audience Creation: Audience creation (English "Custom Audiences") refers to the determination of target groups for advertising purposes, e.g., the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. "Lookalike Audiences" (or similar audiences), in turn, refers to displaying content deemed suitable to users whose profiles or interests are presumably similar to the users for whom the profiles were created. Cookies and web beacons are typically used for the purpose of creating custom audiences and lookalike audiences.