Privacy policy

Introduction

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

We have a separate privacy policy for the processing of personal data in the context of our online presence on social media platforms. You can find this at https://xoros-home.de/datenschutzerklaerung-fuer-social-media-profile/.

The terms used are not gender-specific.

Status: 18/09/2025

Table of contents

• Introduction
• Person responsible
• Overview of processing
• Relevant legal bases
• Security measures
• Transfer and disclosure of personal data
• Data processing in third countries
• Use of cookies
• Commercial and business services
• Payment service provider
• Provision of the online offer and web hosting
• Contact us
• Comments and ratings
• Web analysis, monitoring and optimisation
• Online marketing
• Deletion of data
• Amendment and updating of the privacy policy
• Rights of the data subjects
• Definitions of terms

Person responsible

XOROS Home GmbH
Glockengießerwall 2
20095 Hamburg
Germany
datenschutz@xoros-home.de
+49 40 853 77 201
represented by: Niels Gundermann, Frank Ehlers

Overview of processing

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

Types of data processed

• Inventory data (e.g. names, addresses).
• Content data (e.g. entries in online forms).
• Contact details (e.g. e-mail, telephone numbers).
• Meta/communication data (e.g. device information, IP addresses).
• Usage data (e.g. websites visited, interest in content, access times).
• Location data (information on the geographical position of a device or person).
• Contract data (e.g. subject matter of the contract, term, customer category).
• Payment data (e.g. bank details, invoices, payment history).

Categories of affected persons

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

Purposes of the processing

• Provision of our online services and user-friendliness.
• Visit action evaluation.
• Office and organisational procedures.
• Direct marketing (e.g. by e-mail or post).
• Interest-based and behavioural marketing.
• Contact enquiries and communication.
• Conversion measurement (measurement of the effectiveness of marketing measures).
• Reach measurement (e.g. access statistics, recognition of returning visitors).
• Safety measures.
• Tracking (e.g. interest/behavioural profiling, use of cookies).
• Provision of contractual services and customer service.
• Assessment of creditworthiness and credit standing.
• Managing and responding to enquiries.

Automated decisions in individual cases

• Credit report (decision based on a credit check).

Relevant legal bases

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

• Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.
• Contract fulfilment and pre-contractual enquiries (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.

Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

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

Transfer and disclosure of personal data

As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

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

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

As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions of an online service used. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online offers and to create analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.

Information on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service 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 login status can be saved or favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the user's consent to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained, managed and revoked by the user. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

Cookie consent tool & cookie overview

Further, more detailed information on the cookies we use can be found in the respective cookie policies of our various websites. These also include the so-called cookie consent tool, with which you can manage your consent for cookies of certain types. You will find a link to the cookie policy in the footer area at the bottom of each page.

Commercial and business services

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

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

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years). If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the date on which the cancellation or other termination of the legal relationship takes effect. We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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

Economic analyses and market researchFor business reasons and in order to identify market trends and the wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users, including their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g. as summarised data).

Shop and e-commerceWe process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or fulfilment. If necessary for the fulfilment of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or fulfilment for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is labelled as such in the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultations.

• Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Interested parties, business and contractual partners, customers.
• Purposes of the processing: Provision of contractual services and customer support, Contact requests and communication, Office and organisational procedures, Managing and responding to enquiries, Security measures, Conversion tracking, Interest-based and behavioural marketing, Profiling (Creating user profiles).
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Payment service provider

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

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

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

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

Services used and service providers:

• PayPal: Payment services and solutions (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; Website: https://www.paypal.com/dePrivacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
• Stripe: Payment services and solutions (e.g. credit card payment, SEPA direct debit); Service provider: Stripe Payments Europe, Limited (SPEL), 1 Grand Canal Street Lower, Grand Canal Dock, Dublin D02 H210, Ireland; Website: https://stripe.com/de/Privacy policy: https://stripe.com/de/privacy.

Provision of the online offer and web hosting

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

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

E-mail dispatch and hostingThe web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server.

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

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

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

Contact us

When contacting us (e.g. via contact form, live chat, email, telephone or via social media), the data of the enquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.

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

• Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Persons concerned: Communication partners, interested parties.
• Purposes of the processing: Contact enquiries and communication, administration and answering of enquiries.
• Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services used and service providers:

• Contact form: When users contact us via our contact form, email or other communication channels, we process the data provided to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.
• Hubspot: Management of contact requests and communication; Service provider: HubSpot, Inc, Two Canal Park, Cambridge, MA 02141, USA; Website: https://www.hubspot.dePrivacy policy: https://legal.hubspot.com/de/privacy-policy Basis for third country transfers: standard contractual clauses (https://legal.hubspot.com/de/dpa)

Comments and ratings

When users leave comments or product reviews for publication on our website, we also store the time of their creation in addition to this information. This is for our security, as we can be prosecuted for unlawful content on our website, even if it was created by users. The data you enter is stored for the purpose of personalised communication with you. This requires you to provide a valid e-mail address and your name. This is used to assign the comment or rating and to subsequently reply to the comment or rating.

• Processed data types: Inventory data (e.g. names), contact data (e.g. e-mail), content data (e.g. entries in comment and evaluation forms).
• Persons concerned: Users of the comment or rating functions on our websites.
• Legal basis: The processing of the data entered in the contact form is based on a legitimate interest (Art. 6 para. 1 lit. f DSGVO).
• Purposes of the processing: By providing the comment and product evaluation function, we would like to enable you to interact in an uncomplicated manner. The information you provide will be stored for the purpose of processing the publication and for possible follow-up questions.

Web analysis, monitoring and optimisation

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

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

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

The IP addresses of users are also collected. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored for web analysis, A/B testing and optimisation purposes, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

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

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

Services used and service providers:

• Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users that refer to our online offering and technical aspects of their end devices and browsers.
  Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacyOrder processing contract: https://business.safety.google/adsprocessorterms/Basis for third country transfers: Data Privacy Framework (DPF); opt-out option: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of adverts: https://myadcenter.google.com/personalizationoffFurther information: https://business.safety.google/adsservices/ (Types of processing and data processed).
• Google as the recipient of the consent: The consent given by users in the context of a consent dialogue (also known as "cookie opt-in/consent", 'cookie banner', etc.) fulfils several purposes. On the one hand, it serves to fulfil our obligation to obtain consent to the storage and reading of information on and from the user's end device (in accordance with ePrivacy guidelines). Secondly, it covers the processing of users' personal data in accordance with data protection regulations. In addition, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalised services. We therefore share the status of the consents given by users with Google. Our consent management software informs Google whether consent has been granted or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. In this way, user consents and their revocation in the context of Google Analytics and other Google services in our online offering can be adjusted dynamically and depending on the user selection; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy policy: https://policies.google.com/privacy.

Online marketing

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

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

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

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

In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

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

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

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

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

Services used and service providers:

• Google Ad Manager: We use the "Google Ad Manager" service to place adverts in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager is characterised by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display adverts for our online offering to users who may have a potential interest in our offering or have previously shown an interest in it, and to measure the success of the adverts; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.comPrivacy policy: https://policies.google.com/privacyBasis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/; Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollertermsIf Google acts as a processor, data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
• Google Ads and conversion measurement: Online marketing processes for the purpose of placing content and adverts within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the adverts. In addition, we measure the conversion of the adverts, i.e. whether users have taken them as an opportunity to interact with the adverts and use the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.comPrivacy policy: https://policies.google.com/privacyBasis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Deletion of data

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

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

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

Amendment and updating of the privacy policy

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

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

Rights of the data subjects

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

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

Definitions of terms

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

• Visit action evaluation: "Conversion tracking" refers to a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can track whether the adverts we placed on other websites were successful).
• Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention. According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the fulfilment of a contract or if national laws permit these decisions.
• Cross-device tracking: Cross-device tracking is a form of tracking in which user behaviour and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analysed for marketing purposes, regardless of the browser or device used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
• IP masking: IP masking" refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing procedures, particularly in online marketing
• Interest-based and behavioural marketing: Interest-based and/or behaviour-based marketing is when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and lingering on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
• Conversion measurement: Conversion measurement is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the adverts we have placed on other websites have been successful.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiling: "Profiling" refers to any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognise at what time visitors visit their website and what content they are interested in. This enables them, for example, to better customise the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
• Remarketing: Remarketing" or "retargeting" is when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in adverts.
• Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
• Tracking: The term "tracking" is used when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display adverts to users that are likely to match their interests.
• Responsible person: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, whether it is collecting, analysing, storing, transmitting or deleting.
• Target group formation: Target group formation (or "custom audiences") is the term used when target groups are determined for advertising purposes, e.g. the display of adverts. 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 adverts for similar products or the online shop in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.