Privacy policy

Table of contents

Our privacy policy is structured as follows

  1. General information – Brief introduction to the subject matter of the privacy policy, the controller and the data protection officer
  2. General information on data processing – Information on what personal data is, on what legal basis we process it or share it with third parties
  3. Data subject rights – Information about your rights to, among other things, access, erasure, or object to our data processing
  4. Information about the cookies and other technologies used – Information about the use of cookies and other technologies with which or by means of which we process your personal data
  5. Data processing in connection with the use of our services – Information about our data processing in our services themselves, about registration, and about individual functionalities
  6. Communication Services – Information about communication services and the corresponding processing of your personal data
  7. Provision of our services – Information about our hosting service providers and the services they use
  8. Tracking & Tools – Information about services we use to provide our services to you and to analyze the use of our services
  9. Fan pages on social media – Information about our presence on social media networks and the corresponding processing of your personal data as a result.

1. General

The protection of your personal data and privacy is extremely important to us. That is why we want to offer you comprehensive transparency regarding the processing of your personal data (GDPR) and the storage of information on your device (TDDDG). Only when the processing of personal data and information is transparent to you as the data subject can you be sufficiently informed about the scope, purposes, and benefits of the processing.

This privacy policy applies to all processing of personal data carried out by us and to the storage of information on your end devices. It therefore applies both in the context of the provision of our services and within external online presences, such as our social media fan pages.

The responsible party within the meaning of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and other data protection regulations is


Lawyer Henning Müller
(Professional title: Lawyer)

Neuer Wall 10
20354 Hamburg
Deutschland

Tel: +49 40 356253000
Fax: +49 40 356253025

h.mueller@millbrook-legal.de

Hereinafter referred to as “Controller” or “we.”

2. General information on data processing

First of all, we would like to provide you with some introductory information about what the protection of your personal data means, what personal data is, how we process it, and what security measures we take in doing so.

2.1 Processing of personal data

Personal data (hereinafter also referred to as “data”) is individual information about the personal or factual circumstances of an identified or identifiable natural person.

Specific details about personal or factual circumstances include, for example:

  • Personal data – name, age, marital status, date of birth
  • Contact details – address, telephone number, email address
  • Account details – account number, credit card number
  • Geodata – IP address & location data
  • Health data – Health status, illnesses

The “processing” of personal data includes, for example, the following measures

  • Collection – The collection of your data via contact forms, email, or through processes and services we use.
  • Transfer – Transfer of your data to our service providers, integrated services, or other third parties
  • Storage – The storage of your data in our databases or on our servers
  • Deletion – Deletion of your data when we no longer have permission to process it

2.2 Legal basis for processing your personal data

We only process personal data within the limits permitted by law. We are required to do so by law. In particular, the GDPR. This means that we are obliged to always be able to base data processing operations on a legal basis. These legal bases are standardized in Art. 6 (1) GDPR. Here we list the most common legal bases on which we process your personal data.

  • Consent – Art. 6 (1) (a) GDPR: Your data will only be processed if you have consented to this processing after receiving sufficient information from us about its scope and purposes.
  • For the fulfillment of the contract – Art. 6 para. 1 lit. b: Your data will only be processed if it is necessary for the fulfillment of a contract between us or for the implementation of pre-contractual measures.
  • Legitimate interest – Art. 6 para. 1 lit. f GDPR: Your data will only be processed if this is necessary to safeguard a legitimate interest on our part and if your interests or fundamental rights and freedoms regarding the protection of your data do not outweigh this.

We only process personal data for specific purposes (Art. 5 (1) (b) GDPR). Once the purpose of the processing no longer applies, your personal data will be deleted or protected by technical and organizational measures (e.g., pseudonymization).

The same applies to the expiry of a prescribed storage period, except in cases where further storage is necessary for the conclusion or performance of a contract. In addition, there may be a legal obligation to store data for a longer period or to disclose it to third parties (in particular to law enforcement authorities). In other cases, the storage period and type of data collected, as well as the type of data processing, depend on which functions you use in each individual case. We will be happy to provide you with information on this in individual cases, in accordance with Art. 15 GDPR.

2.3 We process these categories of data

Data categories include the following data in particular:

  • Master data (e.g., names, addresses, dates of birth),
  • Contact details (e.g., email addresses, phone numbers, messenger services),
  • Content data (e.g., text entries, photographs, videos, contents of documents/files),
  • Contract data (e.g., subject matter of the contract, terms, customer category),
  • Payment data (e.g., bank details, payment history, use of other payment service providers),
  • Usage data (e.g., history in our services, use of certain content, access times),
  • Connection data (e.g., device information, IP addresses, URL referrers).

2.4 We take these security measures

In accordance with legal requirements and taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of threats to your rights and freedoms, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring that your data is stored and processed confidentially, with integrity, and is available at all times. Furthermore, controls on access to your data, as well as access, entry, transfer, securing availability, and separation from data belonging to other natural persons are among the security measures we implement. Furthermore, we have established procedures that guarantee the exercise of data subject rights (see section 5), the deletion of data, and responses in the event of a threat to your data. In addition, we take the protection of personal data into account during the development of our software and through procedures that comply with the principle of data protection through technology design and data protection-friendly default settings.

2.5 How we transfer or disclose personal data to third parties

As part of our processing of your personal data, it may happen that this data is transferred or disclosed to other bodies, companies, legally independent organizational units, or individuals. These third parties may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that we have integrated into our services. If we transfer or disclose your personal data to third parties, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

2.6 This is how a transfer to a third country takes place

If this privacy policy states that we transfer your personal data to a third country, i.e. a country outside the EU or the EEA, the following applies. A transfer to a third country will only take place in accordance with the legal requirements. We assure you that we have contractual or legal authorization to transfer and process your data in the third country in question. Furthermore, we only allow your data to be processed by service providers in third countries that, in our opinion, have a recognized level of data protection. This means that there is, for example, an adequacy decision between the EU and the country to which we transfer your personal data. An “adequacy decision” is a decision adopted by the European Commission pursuant to Article 45 GDPR, which determines that a third country (i.e., a country not bound by the GDPR) or an international organization provides an adequate level of protection for personal data. Alternatively, i.e. if there is no adequacy decision, a transfer to a third country will only take place if, for example, contractual obligations between us and the service provider in the third country exist in the form of so-called standard contractual clauses of the EU Commission and further technical security measures have been taken to ensure a level of protection equivalent to that in the EU, or if the service provider in the third country has data protection certifications and your data is only processed in accordance with internal data protection regulations (Articles 44 to 49 GDPR). Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

As part of the so-called “Data Privacy Framework” (“DPF“), the EU Commission has recognized the level of data protection for certain US companies as adequate within the framework of the adequacy decision of July 10, 2023. A 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). In this privacy policy, we inform you which services we use that are certified under the Data Privacy Framework.

2.7 Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent for processing is revoked or other permissions cease to apply (e.g., if the purpose of processing this data no longer applies or it is no longer necessary for the purpose). If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Within the scope of this privacy policy, we provide information on the deletion and storage of data that applies specifically to the respective processing procedures.

2.8 Storage of and access to data on your device

Unless we obtain your consent, the storage of or access to information on your device is carried out in accordance with Section 25 (2) No. 2 of the German Act on Data Protection and Privacy in Telecommunications and Digital Services (TDDDG), as the storage of and access to this information is absolutely necessary to provide the desired functions of our services. If we obtain your consent, the legal basis is Section 25 (1) TDDDG. Our services use cookies, tokens, beacons, or other technologies that may be stored on your end devices and without which the provision of our services would not be possible.

Cookies, tokens, beacons, or other technologies are usually text files that are stored on your device and can be read by us and third parties when you access our services. Many of the aforementioned technologies contain their own ID. Such an ID is a unique identifier for the technology used. It consists of a string of characters that can be used to assign websites and servers to the specific Internet browser or the specific service or device used in which cookies, tokens, beacons, or other technologies were stored. This enables website operators and analysis services to identify you as a user and distinguish you from others.

2.9 Order processing

If we use external service providers to process your data, we carefully select and commission them. If the services provided by these service providers constitute order processing within the meaning of Art. 28 GDPR, the service providers are bound by our instructions and are regularly monitored. Our order processing agreements comply with the strict requirements of Art. 28 GDPR and the specifications of the German data protection authorities.

3. Rights of data subjects

If your personal data is processed, you are a “data subject” within the meaning of the GDPR and, as a data subject, you have the following rights vis-à-vis us as the “controller”:

3.1 Right to information

You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing takes place, you can request the following information from the controller:

  • the purposes for which the personal data are processed;
  • the categories of personal data that are processed;
  • the recipients or categories of recipients to whom your personal data has been or will be disclosed;
  • the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
  • the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
  • the existence of a right of appeal to a supervisory authority;
  • all available information on the origin of the data, if the personal data is not collected from the data subject;
  • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  • You have the right to request information about whether personal data concerning you is being transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

3.2 Right to rectification

You have the right to request the controller to correct and/or complete your personal data if it is inaccurate or incomplete. The controller must make the correction immediately.

3.3 Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions:

  • if you dispute the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • the controller no longer needs the personal data for the purposes of processing, but you need it to assert, exercise, or defend legal claims, or
  • if you have lodged an objection to the processing pursuant to Art. 21(1) GDPR and it is not yet clear whether the legitimate grounds of the controller override your grounds.
  • If the processing of personal data concerning you has been restricted, such data may – apart from its storage – only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

3.4 Right to erasure

3.4.1. You may request that the controller delete your personal data without delay, and the controller is obliged to delete this data without delay if one of the following reasons applies:

  • The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
  • You revoke your consent on which the processing was based in accordance with Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and there is no other legal basis for the processing.
  • You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
  • The personal data concerning you has been processed unlawfully.
  • The erasure of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data concerning you was collected in relation to the information society services offered in accordance with Art. 8 (1) GDPR.

3.4.2. If the controller has made the personal data concerning you public and is obliged to erase it in accordance with Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, taking into account the available technology and the implementation costs, to inform controllers who process the personal data that you, as the data subject, have requested them to delete all links to this personal data or copies or replications of this personal data.

3.4.3. Exceptions to the right to erasure

The right to erasure does not apply if the processing of your data is necessary for the following measures:

  • to exercise the right to freedom of expression and information;
  • to comply with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • to assert, exercise, or defend legal claims.

3.5 Right to information

If you have asserted your right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed by the controller about these recipients.

3.6 Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out using automated means.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another, where technically feasible. This must not adversely affect the freedoms and rights of other persons.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

3.7 Right of objection

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 based on Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the option, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.

3.8 Right to revoke the data protection consent form

You have the right to revoke your declaration of consent under data protection law at any time. Revoking your consent does not affect the legality of the processing carried out on the basis of your consent prior to revocation.

The processing is lawful until you revoke it – the revocation therefore only takes effect on the processing after receipt of your revocation. You can declare the revocation informally by post or email. The processing of your personal data will then no longer take place, subject to permission being granted on another legal basis. If this is not the case, your data must be deleted immediately after revocation in accordance with Art. 17 (2) GDPR. Your right to revoke your consent subject to the above conditions is guaranteed.

Your revocation must be sent to:

Lawyer Henning Müller
(Professional title: Lawyer)

Neuer Wall 10
20354 Hamburg
Deutschland

Tel: +49 40 356253000
Fax: +49 40 356253025

h.mueller@millbrook-legal.de

3.9 Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority to which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

3.10 Automated decisions in individual cases, including profiling

Automated decisions in individual cases, including profiling, are not made unless specifically mentioned in this privacy policy.

3.11 Notification obligations of the controller

If your personal data has been disclosed to other recipients (third parties) on legal grounds, we will notify them of any correction, deletion, or restriction of the processing of your personal data (Art. 16, Art. 17 (1), and Art. 18 GDPR). The obligation to notify does not apply if it involves disproportionate effort or is impossible. We will also inform you about the recipients upon request.

4. Information about the cookies and other technologies used

We use cookies, beacons, and other technologies to provide and evaluate our services and to conduct marketing activities using the evaluated data. Cookies are small text files that contain data from visited websites or domains and are stored on your device (computer, tablet, or smartphone). When you access a website, the cookie stored on your device sends information to the party that placed the cookie.

4.1 How we use cookies and other technologies

We want you to be able to make an informed decision for or against the use of cookies and other technologies that are not strictly necessary for the technical characteristics of the services. Therefore, in the event that we use cookies and other technologies that require your consent, we allow you to choose which cookies and other technologies you allow when you first visit our services and then permanently in the corresponding settings. Please note that functional cookies and other technologies are mandatory for visiting our services and are therefore already permitted via our default settings. Statistics and marketing cookies and other technologies are optional. You can allow them by consenting to the use of these cookies and other technologies in the consent banner. Alternatively, you can reject statistics and marketing cookies and other technologies. Please note that advertising may still be displayed even if you reject the use of statistics and marketing cookies and other technologies. However, this advertising will then be less tailored to your interests. You can still use the full functionality of the services.

4.2 Storage duration of cookies and other technologies

Unless we provide you with explicit information about the storage period for cookies and other technologies (e.g., in the consent banner), you can assume that the storage period may be up to two years. If cookies and other technologies have been set on the basis of your consent, you have the option at any time to revoke your consent or to object to the processing of your data by cookies/technologies (collectively referred to as “opt-out”).

4.3 Types of cookies and other technologies

Objectively, we distinguish between

  • Functional cookies / technologies: These are necessary for the basic technical functions of the services. They enable, for example, secure login and the storage of progress during order processes. They also enable us, for example, to store your login data, the contents of your shopping cart, and the uniform display of page content.
  • Statistics cookies / technologiesThese enable us to analyze the services so that we can measure and improve their performance. You can change your personal settings for statistics by clicking on the corresponding opt-out link.
  • Marketing cookies / technologies: We use these to provide you with advertising that may be relevant to your interests. They enable you, for example, to share pages via social networks and write comments. Offers that may be of interest to you are also displayed. You can change your personal marketing settings by clicking on the corresponding opt-out link.

4.4 Consent management

We use Borlabs as a consent management tool in the context of tracking and analysis activities in our services. Borlabs is a service provided by Borlabs GmbH, Hamburger Str. 11, 22083 Hamburg (” BorlabsBorlabs collects log file and consent data using JavaScript. This JavaScript enables us to inform you about your consent to certain tags in our services and to obtain, manage, and document this consent.

We process the following data: (1) Consent data (anonymized logbook data (consent ID, processor ID, controller ID), consent status, timestamp), (2) Device data (including truncated IP addresses (IP v4, IP v6), device information, timestamp), (3) User data (including email, ID, browser information, setting IDs, changelog). The ConsentID (containing the above data) and the consent status, including timestamp, are stored in your browser’s local memory and simultaneously on the cloud servers we use. Further processing only takes place if you submit a request for information or revoke your consent. We also store personal data that we process using Borlabs on our servers. The legal basis for processing personal data using Borlabs in accordance with the provisions set out here results from our legitimate interest and from the fulfillment of legal requirements, and thus from Art. 6 (1) lit. f and c GDPR. By using Borlabs, we aim to comply with legal requirements for data protection and tracking, thereby ensuring that our information technology systems function in a manner that is both legally compliant and user-centered.

5. Data processing in connection with the use of our services

The use of our services with all their functions involves the processing of personal data. We explain exactly how this happens here.

Informational use of our services

Simply accessing our services for informational purposes requires the processing of the following personal data and information: browser type and version, operating system used, address of previously visited websites, IP address of the device you use to access our services, and the time you accessed our services. All this information is automatically transmitted by your browser unless you have configured it to suppress the transmission of such information.

This personal data is processed for the purpose of ensuring the functionality and optimization of our services, as well as to guarantee the security of our information technology systems. These purposes are also legitimate interests pursuant to Art. 6 (1) lit. f GDPR, meaning that the processing is carried out on a legal basis.

6. Communication Services

6.1 Contact form / Contacting us by email

We process the personal data you provide us with when contacting us for the purpose of responding to your enquiry, email or callback request. The categories of data processed are master data, contact data, content data, usage data (if applicable), connection data and contract data (if applicable). In individual cases, we forward this data to affiliated companies or third parties that we commission to process orders. The legal basis for processing depends on the purpose of the contact. By submitting your request in the contact form or by contacting us by email, you declare that you would like answers or information on specific topics. You also provide your data for this purpose. We will respond to your request as requested and process your data for this purpose. Therefore, the authorization to process your data is based on Art. 6 (1) lit. b GDPR, as we process it to respond to your request and thus to fulfill the contract.

6.2 Applicant management

We process the personal data you provide us with during the application process (e.g., via the corresponding contact/application form in our services) for the purpose of processing your application and carrying out the application procedure. At your request, we will also consider your application for future application procedures. The categories of data processed in this context are master data, contact data, content data, usage data (not for postal applications), connection data (not for postal applications), and contract data. In the case of unsuccessful applications, we delete your data within 3 months of the rejection. In the case of successful applications, we transfer your data to our systems, e.g., to the personnel file. The legal basis for processing your data in the context of applicant management is based on Art. 88 (1) GDPR in conjunction with § 26 (1) sentence 1 BDSG. The legal basis for applying to subsidiaries and for storing data for future application procedures is Art. 6 (1) lit. a GDPR in conjunction with Art. 7 GDPR, Section 26 (2) BDSG; Art. 6 (1) lit. f GDPR.

7. Web hosting

7.1 Provision of our services

In order to provide you with our services, we use the services of a web hosting provider, Raidboxes GmbH, Hafenstraße 32, 48153 Münster, Germany. Our services are accessed from the servers of this web hosting provider. For these purposes, we use the infrastructure and platform services, computing capacity, storage space, and database services, as well as security services and technical maintenance services provided by the web hosting provider.

The processed data includes all data that you enter in connection with your use and communication in connection with your visit to our services or that is collected from you in this context (e.g., your IP address). Our legal basis for using a web hosting provider to provide our services results from Art. 6 (1) lit. f GDPR (legitimate interest).

7.2 Receiving and sending emails

The services we use from the web host may also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients of your emails, the senders, and other information relating to the sending of emails (e.g., the providers involved) as well as the contents of the respective emails are processed. The aforementioned data is processed for purposes including the detection of SPAM. Emails are generally not sent in encrypted form on the Internet. As a rule, emails are encrypted during transport, but (unless end-to-end encryption is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server. Our legal basis for using a web hosting provider to receive and send emails is Art. 6 (1) lit. f GDPR (legitimate interest).

7.3 Collection of access data and log files

We ourselves (or our web hosting provider) collect data on every access to the server (server log files). Server log files may include the address and name of the services and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, your 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 case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability. Our legal basis for using a web hosting provider to collect access data and log files is Art. 6 (1) lit. f GDPR (legitimate interest).

8. Tracking & Tools

To ensure smooth technical operation and optimal user-friendly use of our services, we use the following services:

Google Tag Manager

We use Google Tag Manager in our services. Google Tag Manager is a solution that allows us to manage website tags via an interface and thus integrate other services into our services. Google Tag Manager itself (which implements the tags) does not create profiles or set cookies or other technologies on your device. However, activating Google Tag Manager integrates additional Google services, such as Google Analytics. Data processed when integrating Google Tag Manager includes usage data and connection data. The recipient of the data is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. If Google transfers this data to a third country (e.g., the US), this will only happen in individual cases, on the basis of a data processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for the use of Google Tag Manager is your consent (e.g., via an opt-in in the consent banner), provided that you have given us this consent during your visit to our services, and therefore results from Art. 6 (1) lit. a GDPR. Based on your consent, if additional services are integrated via Google Tag Manager, cookies, so-called “beacons” or similar (text) files may be stored on your device by activating Google Tag Manager, thereby allowing personal data to be read. If you have not given us your consent to use Google Tag Manager (no opt-in in the consent banner or revocation of your consent), we will not (or no longer) use Google Tag Manager when you visit our services. With regard to the processing of personal data by the integrated services, please refer to our explanations on the individual Google services below. The provider of Google Tag Manager is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy.

Google Search Console

For the purpose of continuously optimizing the Google ranking of our services, we use Google Search Console, a web analytics service provided by Google.

Google Search Console allows us to perform search analyses that provide us with information about how often our services appear in Google search results. This enables us to monitor and manage our services in the search index.

When using Google Search Console, no personal user or tracking data is processed or transmitted to Google.

Google Fonts

We use Google Fonts to personalize our services by loading fonts from Google servers. The data processed in this context is usage data and connection data. The recipient of the data is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. If Google transfers this data to a third country (e.g., the US), this will only happen in individual cases, on the basis of a data processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). We use Google Fonts for the purpose of personalizing our services through Google fonts. The data processed here is usage data and connection data. Google Fonts are provided by Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland. The data processed via Google Fonts remains on the servers operated by us or by third parties on our behalf. It is not transferred to other third parties. The legal basis for the use of Google Fonts is Art. 6 (1) lit. f GDPR (legitimate interest). We have an interest in providing you with our services using specially selected fonts. Since we do not pass on your data processed in this way to third parties or link it to other data sources, but process it solely on our systems, your interest in the integrity of your personal data is not unduly impaired.

Google Analytics

We use Google Analytics for the purpose of statistical analysis of your use of our services. We collect your IP address before it is anonymized by Google prior to permanent storage on their servers. Google Analytics enables us to understand how you use our services and how we can improve and develop them accordingly. For example, Google Analytics shows which content you click on or visit repeatedly. The data processed is usage data and connection data. The recipient of the data is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (as joint controller, Art. 26 GDPR). If Google transfers this data to a third country (e.g., the US), this will only happen in individual cases, on the basis of a data processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for the use of Google Analytics is your consent (e.g., via an opt-in in the consent banner), provided that you have given us this consent during your visit to our services, and therefore results from Art. 6 (1) lit. a GDPR. Based on your consent, cookies, so-called “beacons” or similar (text) files are stored on your device and personal data is read out. If you have not given us your consent to use Google Analytics (no opt-in in the consent banner or revocation of your consent), we will not (or no longer) use Google Analytics in connection with your visits to our services.

Google Ad Manager

We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform allows ads to be displayed in real time based on users’ presumed interests. This enables us to display ads in a more targeted manner, presenting you only with ads that correspond to your potential interests. The data processed is usage data and connection data. The recipient of the data is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (as joint controller, Art. 26 GDPR). If Google transfers this data to a third country (e.g., the US), this will only happen in individual cases, on the basis of a data processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for using Google Ad Manager is your consent (e.g., via an opt-in in the consent banner), provided that you have given us this consent when visiting our services, and therefore results from Art. 6 (1) lit. a GDPR. Based on your consent, cookies, so-called “beacons” or similar (text) files are stored on your device and personal data is read out. If you have not given us your consent to use Google Ad Manager (no opt-in in the consent banner or revocation of your consent), we will not (or no longer) use Google Ad Manager when you visit our services.

Google Ads Conversion Tracking

We use Google Ads Conversion Tracking to measure the success of our Google Ads advertising campaigns. First, ads are placed in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who are likely to be interested in the ads. We then measure the conversion of the ads. The only feedback we receive is the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. We ourselves do not receive any information that could be used to identify users. The data processed is usage data and connection data. The recipient of the data is Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (as joint controller, Art. 26 GDPR). If Google transfers this data to a third country (e.g. the USA), this will only happen in individual cases, on the basis of a data processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which guarantee the security of the processing of your personal data with a level of protection identical to that in the EU, in particular on the basis of the EU-US Data Privacy Framework (DPF). The legal basis for the use of Google Ads Conversion Tracking is your consent (e.g., via an opt-in in the consent banner), provided that you have given us this consent during your visit to our services, and tracking therefore results from Art. 6 (1) lit. a GDPR. Based on your consent, cookies, so-called “beacons” or similar (text) files are stored on your device and personal data is read out. If you have not given us your consent to use Google Ads Conversion Tracking (no opt-in in the consent banner or revocation of your consent), we will not (or no longer) use Google Ads Conversion Tracking in connection with your visits to our services.

9. Fan pages on social media websites

We maintain fan pages on social networking websites and process personal data in this context in order to communicate with users active there or to provide information about us. Please note that when you visit our fan pages, your data may be processed outside the European Union. The operators of the respective social networks are responsible for this. A detailed description of the respective forms of processing and the options for objection (e.g., opt-out) can be found in the privacy policies of the operators of the respective social networks.

LinkedIn

We operate a LinkedIn fan page for our company on LinkedIn. When you visit and use the LinkedIn fan page, LinkedIn can evaluate your usage behavior and share the information obtained from this with us. This information is used for the purposes of economic optimization and the needs-based design of our website/services. The categories of data processed here are master data, contact data, content data, usage data, and connection data. The recipient of the data is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, as joint controller in accordance with Art. 26 GDPR. The legal basis for processing the data in accordance with the provisions set out here results from our legitimate interest and thus from Art. 6 (1) lit. f GDPR.

LinkedIn is responsible for implementing your rights as a data subject. LinkedIn will inform you about your rights as a data subject at: https://de.linkedin.com/legal/privacy-policy. You can also assert your rights against us, and we will then forward your request to LinkedIn immediately.

Xing

We operate a Xing fan page for our company on Xing. When you visit and use the LinkedIn fan page, New Work SE can evaluate your usage behavior and share the information obtained with us. This information is used for the purposes of economic optimization and the needs-based design of our website/services. The categories of data processed are master data, contact data, content data, usage data, and connection data. The recipient of the data is New Work SE, Dammtorstraße 30, 20354 Hamburg, as joint controller in accordance with Art. 26 GDPR. The legal basis for processing the data in accordance with the provisions set out here results from our legitimate interest and thus from Art. 6 (1) lit. f GDPR.

Xing is responsible for implementing your rights as a data subject. Xing will inform you about your rights as a data subject at: https://privacy.xing.com/de/datenschutzerklaerung. You can also assert your rights against us, and we will forward your request to Xing immediately.