Privacy policy
PREAMBLE
The following privacy policy is intended to inform you about the types of personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites (www.fpartner.li, www.fpartner.com, www.fpartner.net, www.fpartner.ch, www.fpartner.at, www.fpartner.de), 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.
As of 30 May 2025
TABLE OF CONTENTS
- Preamble
- Responsible
- Contact Data protection officer
- Overview of processing
- Relevant legal basis
- Security
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Business services
- Business processes and procedures
- Providers and services used in the course of business
- Provision of online services and web hosting
- Use of cookies
- Contact and enquiry management
- Communication via messenger
- Video conferencing, online meetings, webinars and screen sharing
- Newsletters and electronic notifications
- Advertising communication via email, post, fax or telephone
- Web analysis, monitoring and optimisation
- Presence on social networks (social media)
- Processing of data within the scope of employment relationships
- Application procedures
- Changes and updates
- Definition of terms
DATA CONTROLLER
Früh & Partners Asset Management Ltd.
Schaanerstrasse 29
9490 Vaduz
Liechtenstein
Email address: info@fpartner.com
Phone: +423 377 99 77
CONTACT DATA PROTECTION OFFICER
Früh & Partners Asset Management Ltd.
Data Protection Officer
Schaanerstrasse 29
9490 Vaduz
Liechtenstein
Phone: +423 377 99 77
Email: datenschutz@fpartner.com
OVERVIEW OF PROCESSING
The following overview summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.
Types of data processed
- Inventory data
- Employee data
- Payment data
- Contact data
- Content data
- Contract data
- Usage data
- Meta, communication and procedural data
- Social data
- Applicant data
- Image and/or video recordings
- Audio recordings
- Log data
- Performance and conduct data
- Working time data
- Salary data
Special categories of data
- Health data
- Religious or philosophical beliefs
- Trade union membership
Categories of data subjects
- Service recipients and clients
- Employees
- Prospective customers
- Communication partners
- Users
- Applicants
- Business and contractual partners
- Clients
- Persons depicted
- Third parties
- Customers
Purposes of processing
- Provision of contractual services and fulfilment of contractual obligations
- Communication
- Security measures
- Direct marketing
- Reach measurement
- Office and organisational procedures
- Conversion measurement
- Organisational and administrative procedures
- Application procedures
- Content delivery network (CDN)
- Feedback
- Marketing
- Profiles with user-related information
- Provision of our online offering and user-friendliness
- Establishment and execution of employment relationships
- Information technology infrastructure
- Financial and payment management
- Public relations
- Sales promotion
- Business processes and business management procedures
RELEVANT LEGAL BASIS
Relevant legal basis according to the GDPR: Below you will find an overview of the legal basis of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are applicable 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 personal data concerning him or her for one or more specific purposes.
- Fulfilment of a contract 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.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severe disability or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under employment law and social security and social protection law and fulfil their obligations in this regard, such processing shall be carried out in accordance with Art. 9(2)(b) GDPR. GDPR, in the case of the protection of the vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for the assessment of the employee's working capacity, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 (2) lit. h. GDPR. In the event of disclosure of special categories of data based on voluntary consent, processing shall be carried out on the basis of Art. 9 para. 2 lit. a GDPR.
- Processing of special categories of personal data relating to health, professional and social security matters (Art. 9(2)(h) GDPR) - Processing is necessary for the purposes of health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, medical care or treatment in the health or social sector, or for the management of systems and services in the health or social sector on the basis of Union law or the law of a Member State or on the basis of a contract with a member of a health profession.
National data protection regulations in Liechtenstein: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Liechtenstein. These include, in particular, the Data Protection Act (DSG) and the Data Protection Ordinance (DSV).
SECURITY MEASURES
We take appropriate technical and organisational measures in accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transfer, availability and separation of the data. Furthermore, we have established procedures to ensure that data subjects can exercise their rights, that data is deleted and that responses are provided in the event of a threat to the data. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technical design and data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies we use and the processing of a complete IP address is not necessary, the IP address is shortened (also known as "IP masking"). In this case, the last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or significantly impede the identification of a person based on their IP address.
Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorised access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorised 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 to users that their data is being transmitted securely and encrypted.
TRANSFER OF PERSONAL DATA
In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure that your data is protected.
Data transfer within the organisation: We may transfer personal data to other departments or units within our organisation or grant them access to it. If the data is transferred for administrative purposes, this is based on our legitimate business and economic interests or is necessary to fulfil our contractual obligations or if the data subject has given their consent or if we have legal permission to do so.
INTERNATIONAL DATA TRANSFERS
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if 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 be done in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers will only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfers (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third-country transfers for the individual providers from the third country, whereby the adequacy decisions take precedence as the basis. Information on transfers to third countries and existing 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. Within the framework 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 adequate within the framework of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you in our data protection notice which service providers we use that are certified under the Data Privacy Framework.
GENERAL INFORMATION ON DATA STORAGE AND DELETION
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there are no further legal grounds for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be retained for commercial or tax 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 data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing operations.
If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply.
If a period does not expressly begin on a specific date and is at least one year, it shall automatically commence at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period shall be the date on which the termination or other termination of the legal relationship takes effect.
Data that is no longer required for the original purpose but is retained due to legal requirements or other reasons will be processed by us exclusively for the reasons that justify its retention.
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
Storage and deletion of data: The statutory retention and deletion periods under Liechtenstein law apply. 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 Articles 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is 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; this also applies to 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 data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the statutory provisions.
- Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with 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 or to request that it be transferred to another controller in accordance with legal requirements.
- Complaint to a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, the supervisory authority of your workplace or the place of the alleged infringement, if you believe that the processing of personal data relating to you violates the GDPR.
The following privacy policy is intended to provide you with an overview of which personal data is processed when you visit the websites of Früh & Partners Asset Management Ltd. (hereinafter referred to as "FP") at www.fpartner.li, www.fpartner.com, www.fpartner.net, www.fpartner.ch, www.fpartner.at, www.fpartner.de.
BUSINESS SERVICES
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), within the scope of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners (or pre-contractual), for example to respond to enquiries.
We use this data to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for administrative tasks associated with these obligations and for company organisation. We also process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or financial authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about further forms of processing, such as for marketing purposes, within the framework of this privacy policy.
We will inform contractual partners of the data required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. for as long as it must be retained for archiving purposes for legal reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.
- 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 email addresses or telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contractual performance and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Financial services: We process our customers' data in order to provide them with advice, brokerage and the conclusion of financial transactions and related services. The necessary information is identified as such in the context of the consultation, brokerage or comparable contract conclusion and includes the information required for the provision of services and billing, as well as contact information to enable us to consult with you if necessary. Insofar as we obtain access to information from customers or other persons, we process this in accordance with the statutory and contractual requirements. Legal basis: Contract performance and pre-contractual enquiries (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).
BUSINESS PROCESSES AND PROCEDURES
Personal data of service recipients and clients – including customers, clients or, in special cases, patients or business partners and other third parties – are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.
The data collected is used to fulfil contractual obligations and to design operational processes efficiently. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the ensuring of internal invoicing and financial processes. In addition, the data supports the protection of the rights of the controller and facilitates administrative tasks and the organisation of the company.
Personal data may be passed on to third parties if this is necessary to fulfil the aforementioned purposes or legal obligations. The data will be deleted after the expiry of the statutory retention periods or when the purpose of processing no longer applies. This also includes data that must be stored for longer periods due to tax and legal documentation requirements.
- 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 email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation); Contract data (e.g. subject matter of the contract, term, customer category); Log data (e.g. log files relating to logins or the retrieval of data or access times); Usage data (e.g. page views and dwell times, 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, persons involved). Employee data (information about employees and other persons in an employment relationship).
- Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services); clients; employees (e.g. employees, applicants, temporary staff and other employees). Customers.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; financial and payment management; security measures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Customer management and customer relationship management (CRM): Processes required in the context of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection requirements, measures to promote customer loyalty and retention, effective customer communication, complaint management and customer service with regard to data protection, data management and analysis to support customer relations, administration of CRM systems, secure account management, customer segmentation and target group formation); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Client management: Procedures required in the context of client management include, for example, the acquisition and registration of new clients, the development of strategies to promote client loyalty, and ensuring effective client communication and appointment scheduling. A comprehensive client service is provided. These procedures also include the maintenance and management of client files, the secure documentation of legal proceedings and ensuring the confidentiality and integrity of client data. In addition, processes are defined for the transfer of client information to third parties, such as courts or other legal service providers. Procedures are in place for the secure and data protection-compliant deletion of client data as soon as it is no longer required or statutory retention periods have expired. Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Contact management and maintenance: Procedures necessary for the organisation, maintenance and securing of contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adjusting contact strategies); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. creation and verification of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of reminders, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable accounting); Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Financial accounting and taxes: Procedures that are necessary for the recording, management and control of financially relevant business transactions and for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of reminders, account reconciliation, tax- e advice, preparation and submission of tax returns, handling of tax matters); Legal basis: Contract fulfilment and pre-contractual enquiries (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).
- Sales: Procedures necessary for the planning, implementation and control of measures for the marketing and sale of products or services (e.g. customer acquisition, preparation and follow-up of offers, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Marketing, advertising and sales promotion: Processes required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Public relations: Procedures required in the context of public relations and public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, preparation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and company websites, corporate branding support); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Guest Wi-Fi: Procedures necessary for the setup, operation, maintenance and monitoring of a wireless network for guests (e.g. installation and configuration of Wi-Fi access points, creation and management of guest accounts, monitoring of the network connection, ensuring network security, troubleshooting connection problems, updating network software, compliance with data protection regulations); Legal basis: Contract performance and pre-contractual enquiries (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).
PROVIDERS AND SERVICES USED IN THE CONTEXT OF BUSINESS ACTIVITIES
Within the scope of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (hereinafter referred to as "services") in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economical management of our business operations and internal organisation.
- 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 email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Business processes and business management procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
PROVISION OF THE ONLINE OFFER AND WEB HOSTING
We process user data in order to provide them with our online services. 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, persons involved); Log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or pictorial messages and contributions, as well as information relating to them, such as details of authorship or time of creation).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures. Content Delivery Network (CDN).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a server provider (also known as a "web host"); Legal basis: 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". The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data 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 prevent server overload (especially in the event of malicious attacks, known as DDoS attacks), and to ensure server utilisation and stability; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data that must be retained for further storage for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
- Swizzonic AG: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data processing agreement: Provided by the service provider; Service provider: Swizzonic AG, Stauffacher, Badenerstrasse 47, CH-8004 Zurich, Switzerland, website: https://www.swizzonic.ch. Privacy policy: https://www.swizzonic.ch/company/legal/privacy-richtlinien/.
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Automattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Microsoft Azure: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://azure.microsoft.com; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Order processing agreement: https://azure.microsoft.com/de-de/support/legal/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Cloudflare: Content Delivery Network (CDN) service that enables the content of an online offering, in particular large media files such as graphics or program scripts, to be delivered more quickly and securely with the aid of regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.cloudflare.com; Privacy policy: https://www.clo udflare.com/privacypolicy/; Order processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Contao: Management of web content, user administration, creation and maintenance of websites, customisation of templates, multilingualism, form generator, file management, search engine optimisation; Service provider: Execution on servers and/or computers under its own data protection responsibility. Website: https://contao.org/.
USE OF COOKIES
The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, such as to ensure the functionality, security and convenience of online services and to analyse visitor traffic. We use cookies in accordance with legal requirements. To do so, we obtain the consent of users in advance, where necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.
Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been 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 duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. This allows, for example, the log-in status to be stored and preferred content to be displayed directly when the user revisits a website. The user data collected using cookies may also be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.
General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including through the privacy settings of their browser.
- Types of data processed: Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: 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 the consent of users for the use of cookies or for the procedures and providers specified in the consent management solution. This procedure serves to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers specified in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (known as an opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information about the providers of consent management services is available, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information about the scope of consent (e.g. categories of cookies and/or service providers) and information about the browser, system and device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- consentmanager: Consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and for processing this information; Service provider: Jaohawi AB, Håltegelvägen 1b, 72348 Västerås, Sweden; website: https://www.consentmanager.de/; privacy policy: https://www.consentmanager.net/; data processing agreement: https://www.consentmanager.net/tac.php. Further information: The following data is stored on the service provider's servers in the EU: Identification number (for the user, their browser, operating system and the device used), IP address, date and time, country, language, type, scope and purpose of consent, browser cookie settings, website on which consent was given, technical information about the browser and operating system.
- Cookiebot: Consent management: Procedure for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and for processing this information; Service provider: Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy policy: https://www.cookiebot.com/de/privacy-policy/; Data processing agreement: Provided by the service provider; Further information: Stored data (on the service provider's server): The user's IP number in anonymised form (the last three digits are set to 0), date and time of consent, browser details, the URL from which the consent was sent, an anonymous, random and encrypted key value, the user's consent status.
CONTACT AND ENQUIRY MANAGEMENT
When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the scope of existing user and business relationships, the details of the persons making the enquiry will be processed to the extent necessary to respond to the contact enquiries and any requested measures.
- 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 telephone numbers); content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation); 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, persons involved).
- Data subjects: Communication partners; service recipients and clients; interested parties; users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collection of feedback via online form); provision of our online offering and user-friendliness; performance of contractual services and fulfilment of contractual obligations; conversion measurement (measurement of the effectiveness of marketing measures); marketing. Office and organisational procedures.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data you provide to respond to and process your enquiry. This usually includes information such as your name, contact details and, if applicable, other information that you provide and that is necessary for the proper processing of your enquiry. We use this data exclusively for the stated purpose of establishing contact and communication; legal bases: fulfilment of a contract and pre- al processing of requests (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Salesforce Service Cloud: Customer management and process and sales support with personalised customer service with multi-channel communication, i.e. management of customer enquiries from various channels as well as analysis and feedback functions; Service provider: salesforce.com Deutschland GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.salesforce.com/de; Privacy policy: https://www.salesforce.com/de/company/privacy; Order processing agreement: https://www.salesforce.com/company/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: Data transfer impact assessment: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf.
- Microsoft Bookings: Online appointment scheduling and management; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) or legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR), depending on the context of use; Website: https://www.microsoft.com/de-de/microsoft-365/bookings; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: Part of the Microsoft privacy agreements within the scope of Microsoft services (in accordance with Art. 28 GDPR); Basis for third-country transfers: Standard contractual clauses in accordance with the EU Commission (see Microsoft privacy policy).
COMMUNICATION VIA MESSENGER
We use messengers for communication purposes and therefore ask you to note the following information regarding the functionality of messengers, encryption, the use of communication metadata and your options for objecting.
You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or those specified within our online offering.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we also inform our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information about the communication partner's device and, depending on the settings of their device, location information (so-called metadata).
Information on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Furthermore, if we do not ask for consent and you contact us on your own initiative, for example, we use Messenger in relation to our contractual partners and within the framework of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilment of our communication partners' needs for communication via Messenger. Furthermore, we would like to point out that we will not transfer the contact data provided to us to the messenger services without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we will delete the messages in accordance with our general deletion guidelines (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.). and otherwise as soon as we can assume that we have answered any questions from the communication partner, if no reference to a previous conversation is to be expected and there are no legal retention obligations that prevent deletion.
Reservation of reference to other communication channels: To ensure your security, we ask for your understanding that we may not be able to respond to enquiries via messenger for certain reasons. This applies to situations in which, for example, contract details must be treated as particularly confidential or a response via messenger does not meet formal requirements. In such cases, we recommend that you use more appropriate communication channels.
- Types of data processed: Contact details (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 details of authorship 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). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Communication partners.
- Purposes of processing: Communication. Direct marketing (e.g. by email or post).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); fulfilment of contract and pre-contractual enquiries (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 iMessage: Send and receive text messages, voice messages and video calls. Have group conversations. Share files, photos, videos and locations. Secure communication through end-to-end encryption. Synchronise messages across multiple devices; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Telegram: Sending and receiving messages, voice calls and video calls; creating groups and channels; sharing files and media; using bots for automation; end-to-end encryption for secret chats; synchronisation across multiple devices; Service provider: Representative in the European Union: European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://telegram.org/. Privacy policy: https://telegram.org/privacy/de.
- WhatsApp: Text messages, voice and video calls, sending images, videos and documents, group chat function, end-to-end encryption for increased security; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.whatsapp.com/; privacy policy: https://www.whatsapp.com/legal. Basis for transfers to third countries: Data Privacy Framework (DPF).
VIDEO CONFERENCES, ONLINE MEETINGS, WEBINARS AND SCREEN SHARING
We use platforms and applications from other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting conference platforms and their services, we comply with the legal requirements.
Data processed by conference platforms: When you join a conference, the conference platforms process the personal data of participants listed below. How much data is processed depends on what data is needed for a specific conference (like login details or real names) and what optional info participants give. In addition to processing for the purpose of holding the conference, the conference platforms may also process participant data for security purposes or to optimise their services. The data processed includes personal data (first name, surname), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information about professional position/function, the IP address of the Internet access, information about the participants' end devices, their operating system, browser and its technical and language settings, information about the content of communication processes, i.e. entries in chats as well as audio and video data, and the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference provider. If participants are registered as users on the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recording: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, participants will be informed of this in advance in a transparent manner and, where necessary, asked for their consent.
Data protection measures taken by participants: Please refer to the data protection information provided by the conference platforms for details on how your data is processed and select the security and data protection settings that are best for you in the conference platform settings. Please also ensure that your data and privacy are protected in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and, where technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.
Information on legal bases: If, in addition to the conference platforms, we also process user data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing meeting results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- 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 telephone numbers); Content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); Image and/or video recordings (e.g. photographs or video recordings of a person); audio recordings; log data (e.g. log files relating to logins or the retrieval of data or access times). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services); persons depicted. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; marketing. Provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.microsoft.com/de-de/microsoft-teams/; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter. Basis for transfers to third countries: Data Privacy Framework (DPF).
- 3CX: Chat functions, video and audio conferences; Service provider: 3CX GmbH, Walter-Gieseking-Straße 22, 30519 Hanover, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.3cx.de/. Privacy policy: https://www.3cx.com/company/privacy/.
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter referred to as "newsletters") exclusively with the consent of the recipients or on the basis of a legal basis. If the content of the newsletter is specified when registering for the newsletter, this content is decisive for the consent of the users. To subscribe to our newsletter, it is usually sufficient to provide your email address. However, in order to provide you with a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently comply with objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose only.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.
CONTENTS:
Information about us, our services, promotions and offers.
- 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 telephone numbers); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved); Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Mailchimp: Email marketing, automation of marketing processes, collection, storage and management of contact data, measurement of campaign performance, recording and analysis of recipients' interaction with content, personalisation of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider), Data Privacy Framework (DPF) Standard Contractual Clauses (provided by the service provider); Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
- Salesforce: Email delivery and automation services; Service provider: salesforce.com Deutschland GmbH, Erika-Mann-Str. 31, 80636 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.salesforce.com/de/; Privacy policy: https://www.salesforce.com/de/company/privacy/; Data processing agreement: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Agreements/data-processing-addendum.pdf; Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000KzLyAAK&status=Active), Data Privacy Framework (DPF) Standard Contractual Clauses (https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000KzLyAAK&status=Active); Further information: Data Transfer Impact Assessment &
Salesforce Services: https://www.salesforce.com/content/dam/web/en_us/www/documents/legal/Privacy/dpia-and-salesforce-services.pdf.
ADVERTISING COMMUNICATION VIA E-MAIL, POST, FAX OR TELEPHONE
We process personal data for the purposes of advertising communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke their consent at any time or to object to advertising communications at any time.
After revocation or objection, we will store the data necessary to prove the previous authorisation for contacting or sending information for up to three years after the end of the calendar year in which the revocation or objection was made on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid renewed contact (e.g. depending on the communication channel, the email address, telephone 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 telephone numbers). Content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g. by email or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
WEB ANALYSIS, MONITORING AND OPTIMISATION
Web analysis (also referred to as "reach measurement") is used to evaluate visitor flows 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, identify at what times our online offering or its functions or content are used most frequently, or invite visitors to return. It also enables us to identify areas that require optimisation.
In addition to web analysis, we may also use testing procedures to test and optimise different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as 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 by us or by the providers of the services we use, the processing of location data is also possible.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of 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.
- Types of data processed: Usage data (e.g. page views and length of stay, 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, persons involved).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- 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 email addresses. It is used to assign analysis information to a terminal device in order to recognise which content users have accessed within one or more usage sessions, which search terms they have used, which content they have accessed again or how they have interacted with our online offering. The time of use and duration of use are also stored, as well as the sources of users who refer to our online offering and technical aspects of their terminal devices and browsers.
Pseudonymous user profiles are created using information from the use of different devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based equivalents). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being deleted immediately. It is not logged, is not accessible and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU- -based servers before 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/privacy; order processing agreement: https://business.safety.google/adsprocessorterms/; basis for third-country transfers: Data Privacy Framework (DPF); option to object (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed). - Google Tag Manager: We use Google Tag Manager, a piece of software from Google that allows us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that are used to record and analyse visitor activity. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies with user profiles or carry out independent analyses. Its function is limited to simplifying and making the integration and management of tools and services that we use on our website more efficient. Nevertheless, when using Google Tag Manager, the IP address of the user is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via Tag Manager. For more detailed information about these services and their data processing, please refer to the further sections of this privacy policy; 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; Privacy policy: https://policies.google.com/privacy; Order processing agreement:
https://business.safety.google/adsprocessorterms. Basis for transfers to third countries: Data Privacy Framework (DPF).
PRESENCE ON SOCIAL NETWORKS (SOCIAL MEDIA)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, as it could, for example, make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are believed to correspond to the interests of users . For this reason, cookies are usually stored on users' computers, in which the usage behaviour and interests of users are stored. In addition, data may also be stored in the usage profiles independently of the devices used by users (in particular if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the event of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. However, if you require assistance, please contact us.
- Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Communication; feedback (e.g. collection of feedback via online form). Public relations.
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size and employment status. Information on data protection for the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6(1)(f) GDPR); privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF). Right to object (opt-out): https://myadcenter.google.com/personalizationoff.
PROCESSING OF DATA IN THE CONTEXT OF EMPLOYMENT RELATIONSHIPS
Within the scope of employment relationships, personal data is processed for the purpose of effectively establishing, implementing and terminating such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relationships.
Data processing covers various aspects ranging from contract initiation to contract termination. This includes the organisation and administration of daily working hours, the management of access rights and authorisations, and the handling of personnel development measures and employee appraisals. Processing also serves the purpose of accounting and administering wage and salary payments, which are critical aspects of contract execution.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or recording performance data for the evaluation and optimisation of operational processes. Furthermore, data processing includes the disclosure of employee data in the context of external communication and publication processes, where this is necessary for operational or legal purposes.
This data is always processed in compliance with the applicable legal framework, with the aim of creating and maintaining a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, anonymising or deleting data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.
- Types of data processed: Employee data (information about employees and other persons in an employment relationship); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category); Inventory data (e.g. full name, residential address, contact information, customer number, etc.); 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 details of authorship or time of creation); Social data (data subject to social secrecy and processed, for example, by social security institutions, social welfare agencies or pension authorities); Log data (e.g. log files relating to logins or the retrieval of data or access times); Performance and behaviour data (e.g. performance and behaviour aspects such as performance reviews, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behaviour assessments); Working time data (e.g. start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); Salary data (e.g. basic salary, bonus payments, premiums, tax class information, allowances for night work/overtime, tax deductions, social security contributions, net pay); Image and/or video recordings (e.g. photographs or video recordings of a person); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).
- Special categories of personal data: Health data; religious or philosophical beliefs. Trade union membership.
- Data subjects: Employees (e.g. employees, applicants, temporary staff and other employees).
- Purposes of processing: Establishment and performance of employment relationships (processing of employee data in the context of establishing and performing employment relationships); business processes and business procedures; provision of contractual services and fulfilment of contractual obligations; public relations; security measures. Office and organisational procedures.
- Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR). Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
FURTHER INFORMATION ON PROCESSING PROCESSES, PROCEDURES AND SERVICES:
- Working time recording: Procedures for recording the working hours of employees include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. Activities such as entering arrival and departure times, break times, overtime and absences are carried out. Verification and validation of the recorded working hours include comparison with work schedules or shift schedules, checking absences and approval of overtime by supervisors. Reports and analyses are generated on the basis of the recorded working hours to provide timesheets, overtime reports and absence statistics for management and the human resources department. Legal basis: Contract fulfilment and pre- al processing for contractual purposes (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Authorisation management: Procedures required for the definition, management and control of access rights and user roles within a system or organisation (e.g. creation of authorisation profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal bases: Contract performance and pre-contractual enquiries (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).
- Special categories of personal data: Special categories of personal data are processed within the scope of the employment relationship or to fulfil legal obligations. The special categories of personal data processed include data concerning the health, trade union membership or religious affiliation of employees. This data may be passed on to health insurance companies, for example, or processed for the purpose of assessing the fitness for work of employees, for occupational health management or for providing information to the tax authorities. Legal basis: Fulfilment of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Sources of the processed data: Personal data obtained in the context of the application and/or employment relationship of the employees is processed. In addition, personal data is collected from other sources if required by law. These may include tax authorities for tax-related information, the relevant health insurance fund for information on incapacity to work, third parties such as employment agencies or publicly accessible sources such as professional social networks in the context of application procedures. Legal basis: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Purposes of data processing: The personal data of employees is primarily processed for the establishment, implementation and termination of the employment relationship. In addition, the processing of this data is necessary to fulfil legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfil regulatory and supervisory requirements, to optimise electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defence in legal disputes. Legal bases: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Transfer of employee data: Employee data is only processed internally by those departments that require it to fulfil operational, contractual , and legal obligations.
Data will only be transferred to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this include requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients to the extent necessary to fulfil its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance funds, pension insurance institutions, pension providers and other social insurance institutions c) Authorities, courts (e.g. tax authorities, labour courts, other supervisory authorities within the scope of their reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of wage and salary garnishments f) Other bodies to which legally binding declarations must be made.
In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this are information in the sender field of emails or letterheads and the creation of profiles on external platforms; legal bases: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - Transfer of employee data to third countries: Employee data will only be transferred to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), if this is necessary for the fulfilment of the employment relationship, is required by law or if employees have given their consent. Employees will be informed separately about the details, where required by law; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Business trips and travel expense reports: Procedures required for planning, executing and accounting for business trips (e.g. booking trips, organising accommodation and transport, managing travel expense advances, submitting and reviewing travel expense reports, checking and posting incurred costs, complying with travel guidelines, handling travel expense management); Legal basis: Contract performance and pre-contractual enquiries (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).
- Payroll accounting and payroll administration: Procedures required for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. recording working hours, calculating deductions and allowances, paying taxes and social security contributions, preparing wage and salary statements, maintaining wage accounts, reporting to tax authorities and social security institutions); Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Deletion of employee data: Employee data will be deleted in accordance with Liechtenstein law if it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer . Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR), processing of special categories of personal data relating to health, professional and social security (Art. 9 (2) (h) GDPR).
- Personnel file management: Procedures necessary for the organisation, updating and management of employee data and documents (e.g. recording of personnel master data, storage of employment contracts, references and certificates, updating of data in the event of changes, compilation of documents for employee appraisals, archiving of personnel files, compliance with data protection regulations); Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6(1)(f) GDPR), processing of special categories of personal data relating to health, professional and social security (Art. 9(2)(h) GDPR).
- Personnel development, performance evaluation and employee appraisals: Procedures that are necessary in the area of promoting and developing employees, as well as in assessing their performance and in the context of employee appraisals (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, conducting target agreement and feedback meetings, career planning and talent management, succession planning); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), processing of special categories of personal data relating to health, profession and social security (Art. 9 para. 2 lit. h) GDPR).
- Obligation to provide data: The controller informs employees that the provision of their data is necessary. This is generally the case if the data is necessary for the establishment and performance of the employment relationship or if its collection is required by law. The provision of data may also be necessary if employees assert claims or if claims are due to employees. The implementation of these measures or the performance of services is dependent on the provision of this data (e.g. the provision of data for the purpose of receiving wages). Legal basis: Fulfilment of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers in accordance with an agreement or agreed job description, or if the job description includes representative functions. This may also be the case if, in the course of performing their duties, employees are presented or communicate with the public, such as when photographs are taken for public relations purposes. Otherwise, employee data will only be published with their consent or on the basis of the employer's legitimate interests, e.g. in the case of stage or group photographs taken during a public event. Legal basis: Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
APPLICATION PROCESS
The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required is specified in the job description or, in the case of online forms, in the information provided there.
As a rule, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. Upon request, we will be happy to provide further information on the details required.
If available, applicants are welcome to submit their applications via our online form, which is encrypted using the latest technology. Alternatively, it is also possible to send applications to us by email. However, we would like to point out that emails are generally not encrypted when sent over the Internet. Although emails are usually encrypted during transmission, this is not the case on the servers from which they are sent and received. We therefore cannot accept any responsibility for the security of your application during transmission between the sender and our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services provided by third parties in accordance with the statutory requirements.
Applicants are welcome to contact us regarding the method of submitting their application or send us their application by post.
Processing of special categories of data: If special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severe disability or ethnic origin) are requested from applicants or provided by them, this data will be processed so that the controller or the data subject can exercise their rights under employment law and social security and social protection law and fulfil their obligations in this regard, in the case of the protection of the vital interests of the applicants or other persons or for the purposes of health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, for the provision of care or treatment in the health or social sector or for the management of systems and services in the health or social sector.
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job vacancy is unsuccessful, the applicant's data will be deleted. The applicant's data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicant, the data will be deleted at the latest after a period of six months so that we can answer any follow-up questions regarding the application and fulfil our obligations under the German General Data Protection Regulation ( ) regarding equal treatment of applicants. Invoices for any travel expenses will be archived in accordance with tax regulations.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can withdraw their consent at any time in the future.
Duration of data storage in the applicant pool in months: 3 months
- 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 telephone numbers); content data (e.g. textual or pictorial messages and posts, as well as information relating to them, such as details of authorship or time of creation). Applicant data (e.g. personal details, postal and contact addresses, documents relating to the application and the information contained therein, such as cover letters, CVs, references and other information provided by applicants in relation to a specific position or voluntarily provided by applicants about themselves or their qualifications).
- Data subjects: Applicants.
- Purposes of processing: Application process (justification and any subsequent implementation and possible subsequent termination of the employment relationship).
- Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
- Legal basis: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).
CHANGES AND UPDATES
We ask you to regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact information for companies and organisations in this privacy policy, please note that addresses may change over time and check the details before contacting them.
Our competent supervisory authority:
Data Protection Authority Liechtenstein
Städtle 38
FL-9490 Vaduz
Principality of Liechtenstein
Tel. +423 236 60 90
Email: info.dss@llv.li
DEFINITION OF TERMS
This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their legal definitions apply. The following explanations are intended primarily to aid understanding.
- Employees: Employees are persons who are in an employment relationship, whether as staff members, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs his or her work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee carries out their work, and the termination, when the employment relationship ends, whether through dismissal, termination by mutual agreement or otherwise. Employee data is all information relating to these individuals and relevant to their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
- Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include 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, facilities or systems by enabling unique identification and communication.
- Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service that helps deliver content from an online offering, especially large media files such as graphics or program scripts, more quickly and securely using regionally distributed servers connected via the Internet.
- Content data: Content data includes information generated during the creation, editing and publication of all types of content. This category of data can include text, 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, such as tags, descriptions, author information and publication dates.
- Contact data: Contact data is essential information that enables communication with individuals or organisations. It includes telephone numbers, postal addresses and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
- Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. To do this, a cookie is usually stored on the user's device within the websites where the marketing measures are carried out and then retrieved again on the target website. For example, this allows us to track whether the ads we place on other websites were successful at .
- Performance and behavioural data: Performance and behavioural data refers to information related to how individuals perform tasks or behave in a particular context, such as in an educational, work or social environment. This data may include metrics such as productivity, efficiency, work quality, attendance and compliance with policies or procedures. Behavioural data could include interactions with colleagues, communication styles, decision-making processes and responses to various situations. These types of data are often used for performance evaluations, training and development measures, and decision-making within organisations.
- 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 that describes the context, origin and structure of other data. It can include details such as file size, creation date, author of a document, and change history. Communication data captures the exchange of information between users across various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission routes. Process data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify processes.
- 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 how they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- Personal data: "Personal data" is any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or 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, includes 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 may include different information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.). 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 time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor flows 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, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them, for example, to better tailor the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis to recognise returning visitors and thus obtain more accurate analyses of the use of an online offering.
- Controller: 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 performed on personal data, whether or not by automated means. The term is broad and covers virtually all handling of data, whether it is collection, evaluation, storage, transmission or deletion.
- Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the terms and conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed upon, price agreements, payment terms, termination rights, renewal options, and special conditions or clauses. It serves as the legal basis for the contract 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 crucial 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 data, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorisations and fees.