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Privacy policy

§ 1 Information on the collection of personal data

(1) In the following, we inform you about the collection of personal data when using our website and our other presences and appearances and within the scope of our services. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses, user behavior. This data protection declaration applies to those appearances and offers through which it is made available. Different data protection information may apply to our other presences and services.

(2) The responsible party pursuant to Art. 4 (7) EU General Data Protection Regulation (GDPR) is the

Neue fische GmbH

Gasstraße 6a

22761 Hamburg

You can find further contact information for us in our provider identification ("Imprint").

You can reach our company data protection officer at the aforementioned contact details with the addition of the letter "Der/die Datenschutzbeauftragte" or by e-mail at datenschutz@neuefische.de.

(3) When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations. The legal basis for processing your data in the context of communication with you is the existence of consent Art. 6 Paragraph 1 Letter a GDPR. If the communication serves to fulfill a contract with you or to carry out pre-contractual measures, the legal basis for the processing of your data is Art. 6 Para. 1 lit. b GDPR, in all other cases our legitimate interest in efficient, customer-friendly and targeted processing your concern in connection with Art. 6 Para. 1 lit. f) GDPR as well as any other obligation that may be incumbent on us legal obligation that requires the storage and processing of your data, in conjunction with Article 6 paragraph 1 lit. c) GDPR.

§ 2 Your rights

(1) You have the following rights against us regarding the personal data concerning you:

- Right to information,

- Right to rectification or deletion,

- Right to restriction of processing,

- Right to object to processing,

- Right to data portability.

(2) You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

§ 3 Collection of personal data when visiting our website

(1) In the case of mere informational use of the website, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6 para. 1 p. 1 lit. f GDPR):

- IP address

- Date and time of the request

- Time zone difference from Greenwich Mean Time (GMT)

- Content of the request (concrete page)

- Access status/HTTP status code

- Data volume transferred in each case

- Website from which the request comes

- Browser

- Operating system and its interface

- Language and version of the browser software.

(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which the body that sets the cookie (here by us), certain information flows. Cookies cannot execute programs or transfer viruses to your computer. They serve to make the Internet offer as a whole more user-friendly and effective.

(3) Use of cookies:

Our websites use cookies and similar technologies. Cookies are small text files that are stored by the Internet browser on the user's terminal device. A cookie usually contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. 

Cookies are used to make the website more user-friendly, to optimize the functions and services of the website and to provide you with content tailored to your needs. 

The purpose of using technically necessary cookies is to enable and simplify the use of the website and functions provided with it. Some functions of this website cannot be offered without the use of cookies. 

The user data collected through technically necessary cookies are not used to create user profiles.

In addition, with your separate consent, cookies may be used for the provision of external media such as movies and maps, as well as for the analysis of the use of the website and other functions. 

By changing the settings in your Internet browser, you can disable or restrict the use of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for the website, it may no longer be possible to use all functions of the website in full.

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 (1) lit. f GDPR, whereby the legitimate interest of the controller is the secure, stable, efficient provision of the functions of the website and the information that can be accessed via it. If the responsible party fulfills a contractual obligation to you with the respective function, the legal basis is Art. 6 (1) lit. b GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes as well as for other processing purposes that are not technically necessary is, if the user has given his consent in this regard, Art. 6 (1) lit. a GDPR in conjunction with Section 25 TTDSG.

§ 4 Further functions and offers

(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you usually have to provide further personal data, which we use to provide the respective service and for which the aforementioned data processing principles apply.

(2) We may pass on your personal data to third parties if we offer participation in promotions, competitions, conclusion of contracts or similar services together with partners the transfer is necessary for the respective purpose. You will receive more information about this when you provide your personal data or below in the description of the offer.

(3) For the proper provision of the content of this website, we use the Contentful CDN (Content Delivery Network) of Contentful GmbH, Ritterstraße 12-14, 10969 Berlin (Contentful). The Contentful CDN helps to make content, in particular files such as graphics or videos, available to you more quickly with the help of regionally or internationally distributed servers.

When using our website, Contentful processes in particular the IP address, user agent and browser information.


Your data will be stored by Contentful for a maximum of 90 days.

Storage and processing takes place on servers in the EU, the United States of America or other third countries in accordance with GDPR on the basis of closed EU standard contractual clauses (SCC). Personal Data may be shared with service providers and their affiliates who provide technology or ancillary services to support, operate and maintain Contentful Services.

The legal basis for the processing of the data is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, whereby our legitimate interest is the one mentioned above
processing purposes.

You can object to the collection and storage of data at any time with effect for the future. To object to data collection and storage of your data for the future, you can click on the following link: https://www.contentful.com/legal/privacy-at-contentful/do-not-sell-data-access-request/ 

Please note that this may result in content no longer being displayed correctly or not at all and that the functions of this website may be restricted as a result.

For further details on data processing, please refer to Contentful's privacy policy: https://www.contentful.com/legal/privacy-at-contentful/privacy-notice/ 

(4) We use the technical solution Userlike (hereinafter "Userlike") to process user inquiries and for customer communication via live chat systems. The provider is Userlike UG (limited liability), Probsteigasse 44 – 46, 50670 Cologne. Userlike is a live chat and communication solution that can be used in particular to conduct live chats when visiting our website. Personal data is also processed here, in particular the content of messages and technical information that is required for processing the communication and the technical operation of the communication solution.

Messages that you send to us can be saved in the Userlike ticket system or answered in live chat by our employees. If you communicate with us via Userlike, we and Userlike store u. a. Your name and email address, if you have provided them, and your chat history. This data is summarized in a profile.

The messages addressed to us remain with us until you ask us to delete them or the purpose for data storage no longer applies (e.g. after your request has been processed or other related business transactions have been completed; if any information required to provide evidence is provided the deletion after the end of the statutory limitation periods for possible claims). Mandatory legal provisions - in particular statutory retention periods - remain unaffected.

Userlike is used on the basis of Article 6 (1) (f) GDPR. We have a legitimate interest in processing your inquiries as quickly, directly, reliably and efficiently as possible. If a corresponding consent was requested, the processing takes place exclusively on the basis of Art. 6 Para. 1 lit. a DSGVO and § 25 Para B. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Further information can be found in Userlike's data protection declaration: https://www.userlike.com/de/data-privacy and https://www.userlike.com/de/blog/live-chat-software-datenschutz-dsgvo.

(5) On our website and as part of other websites, we offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. A transfer of data to third parties does not take place. As part of the registration process, the information resulting from the registration form is requested and stored by us. The legal basis for the processing of the data, if the user has given his consent, is Article 6 (1) (a) GDPR. If the registration of the performance of a contract to which the data subject is a party, or the implementation is used for pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 Para. 1 lit. b GDPR.

§ 5 Objection or revocation against the processing of your data

(1) If you have given your consent to the processing of your data, you may revoke this consent at any time. Such revocation affects the permissibility of processing your personal data after you have expressed it to us.

(2) Insofar as we base the processing of your personal data on the balance of interests, you may object to the processing. This is the case if the processing is not necessary, in particular, for the fulfillment of a contract with you, which is presented by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will review the situation and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing.

(3) Of course, you can object to the processing of your personal data for purposes of advertising and data analysis at any time. You can inform us of your objection to advertising using the contact details provided above.

§ 6 Web tracking

Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google Ireland Ltd ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated thereby about your use of the website will be transmitted to and stored by Google on servers in the United States. In the event that IP anonymization is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

(4) This website uses Google Analytics with the extension "_anonymizeIp()". This means that IP addresses are processed in abbreviated form, which means that personal references can be ruled out. Insofar as the data collected about you is related to a person, this is therefore immediately excluded and the personal data is thus immediately deleted.

(5) We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offer and make it more interesting for you as a user. 

(6) Third Party Provider Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User Terms: https://marketingplatform.google.com/about/analytics/terms/us/, Privacy Policy Overview: https://marketingplatform.google.com/intl/en_uk/about/, and Privacy Policy: http://www.google.de/intl/de/policies/privacy.

For the possible cases in which personal data is transferred to the USA, Google complies with the data protection requirements for data transfer to third countries pursuant to Art. 44 et seq. GDPR. For this purpose, so-called EU standard contractual clauses have been concluded. You can view these here: https://policies.google.com/privacy/frameworks?hl=en

(6) Web analysis and optimization with the help of the service Hotjar, the third-party provider Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe. Hotjar can be used to track movements on the websites on which Hotjar is used (so-called heat maps). For example, it is possible to see how far users scroll and which buttons users click on and how often. Furthermore, technical data such as the selected language, system, screen resolution and browser type are recorded. In this way, user profiles can be created, at least temporarily, during the visit to our website. Furthermore, with the help of Hotjar, it is also possible to obtain feedback directly from the users of the website. In this way, we obtain valuable information to make our websites even faster and more customer-friendly. This is also our legitimate interest under the legal basis of Art. 6 (1) p. 1 lit. f GDPR) Privacy Policy: www.hotjar.com/privacy. Opt-Out: www.hotjar.com/opt-out.

Google Tag Manager

This website uses the Tag Manager from Google. This service allows us to manage website tags through one interface. This Google tool only sets tags. This means that no cookies are used and no personal data is regularly collected in the process. However, this may trigger other tags, which in turn may collect data. The Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, this remains in place for all tracking tags when they are implemented with the Google Tag Manager.

Matomo

This website uses the analysis tool Matomo, an open source web analysis tool (https://matomo.org/)

We use the open source tool Matomo to analyze our website. The purpose of the data processing is an analysis of your surfing behavior. By evaluating the data obtained, we are able to compile information about the use of the individual pages of our website. This helps us to improve our website and its user-friendliness.

Basically, a consent-free and completely anonymized tracking is established, which is supplemented by an extended consent-required tracking based on cookies. The legal basis for the processing of data, which is carried out by setting cookies and thus accessing the end device, is your consent in accordance with Art. 6 (1) a of the GDPR. This procedure takes into account all current data protection requirements. A third tracking (census measurement) determines the absolute number of page views on the server side independently of the previously integrated and possibly rejected tracking variants.

The Matomo software runs exclusively on the server of our service provider. Your personal data is only stored there. The data is not passed on to third parties. 

The software is set so that the IP addresses are not stored completely, but 2 bytes of the IP address are masked (Ex: 192.168.xxx.xxx). In this way, an assignment of the shortened IP address to the calling computer is no longer possible.

You have the option at any time to revoke the consent you have given to the setting of cookies via the cookie management functions of the website. In addition, you have the option of preventing consent-free tracking by calling up the data protection declaration and excluding consent-free tracking with effect for the future under "Prevent tracking". This revocation does not affect the lawfulness of the processing of the data that has taken place to date.

Matomo Tag Manager

We use the tag manager to integrate the analysis tool Matomo Analytics. The conversion pixels of our Meta and TikTok social media channels are also integrated via the tag manager. In addition, the tag manager is used to tag the form path for competition participation so that we can better measure the progress of the form.

Prevent tracking

Deactivate the user analysis by setting the checkbox for the opt-out for cookieless tracking. A cookie will then be set that stores your privacy preferences. Your visits to this website will then no longer be collected by the web analytics tool. Please note that the Matomo deactivation cookie of this website will also be deleted if you remove the cookies stored in your browser. Moreover, if you use a different computer or a different web browser, you will have to repeat the deactivation procedure.

Opt-out from cookieless tracking

§ 7 Usage-based and advertising content

Google Ads

We use "Google Ads" (formerly Google AdWords) on our website, a service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google Ads enables us to draw attention to our attractive offers with the help of advertising media on external websites. This enables us to determine how successful individual advertising measures are. These advertising media are delivered by Google via so-called "AdServers". For this purpose, we use so-called AdServer cookies, which can be used to measure certain parameters for measuring success, such as display of the ads or clicks by users. If you access our website via a Google ad, Google Ads will store a cookie on your PC. These cookies usually lose their validity after 30 days. They are not intended to identify you personally. The following information is usually stored as analysis values for this cookie: unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions), opt-out information (marking that the user no longer wishes to be addressed). These cookies enable Google to recognize your web browser. If a user visits certain pages of an Ads customer's website and the cookie stored on their computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each Ads customer. Cookies can therefore not be tracked across Ads customers' websites. We ourselves do not collect or process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can see which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising tools; in particular, we cannot identify users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with Google's server. We have no influence on the scope and further use of the data collected by Google through the use of Google Ads. According to our knowledge, Google receives the information that you have called up the relevant part of our website or clicked on an ad from us. If you have a user account with Google and are registered, Google can assign the visit to your user account. Even if you are not registered with Google or have not logged in, there is the possibility that Google learns your IP address and stores it.

We use Google Ads for marketing and optimization purposes, in particular to serve relevant and interesting ads to you, to improve campaign performance reports and to achieve a fair calculation of advertising costs. This is also our legitimate interest in the processing of the above data by the third-party provider. The legal basis is Art. 6 para. 1 p. 1 lit. f) GDPR and, insofar as we obtain your consent, Art. 6 para. 1 lit. a GDPR.

You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in the settings of your web browser. We would like to point out that in this case you may not be able to use all functions of our website to their full extent. It is also possible to prevent the storage of cookies by setting your web browser to block cookies from the domain "www.googleadservices.com" (https://www.google.de/settings/ads). We would like to point out that this setting will be deleted when you delete your cookies. In addition, you can deactivate interest-based ads via the link https://optout.aboutads.info. We would like to point out that this setting will also be deleted when you delete your cookies.

We also use the Enhanced Conversions feature from Google Ads to optimize our advertising measures via Google and in the Google advertising network and to be able to better control and measure their success. Data can be used to better identify groups of people within the Google advertising network who are most likely to want to carry out or initiate conversion events (e.g. signing contracts) via our website. This is done by transmitting your known email addresses and telephone numbers (email addresses and telephone numbers mathematically hidden, i.e. “hashed”) to Google after you have completed a conversion event (e.g. conclusion of a contract or expression of interest in our services) on our website website.

Third-party information: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland

Further information on data use by Google, on setting and objection options, and on data protection can be found on the following Google web pages:

Privacy policy: https://policies.google.com/privacy?hl=en&gl=de

Google website statistics: https://services.google.com/sitestats/de.html 

Facebook Pixel

This website uses the visitor action pixel from Facebook for conversion measurement. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the USA and other third countries.

This allows the behavior of page visitors to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.

The collected data is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook data usage policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.

The use of Facebook Pixel is based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media. If a corresponding consent has been requested (e.g. consent to store cookies), the processing is based exclusively on Art. 6 (1) lit. a GDPR; the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

You can find more information about protecting your privacy in Facebook's privacy policy: https://de-de.facebook.com/about/privacy/.

You can also disable the Custom Audiences remarketing feature in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.

If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.

Facebook Custom Audience

We use on our site the service Custom Audiences of the company Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, 2 Dublin, Ireland, e-mail: impressum-support@support.facebook.com, website: facebook.com. The processing also takes place in a third country for which there is no Commission adequacy decision. Therefore, the usual level of protection for the GDPR cannot be guaranteed for the transfer, as it cannot be ruled out that in the third country, e.g. authorities can access the collected data. The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/terms/customaudience and https://www.facebook.com/legal/terms/dataprocessing.

The legal basis for the transmission of personal data is your consent pursuant to Art. 6 para. 1 lit. a GDPR, which you can revoke at any time via the cookie settings of this website.

Facebook Custom Audience is an advertising tool from Facebook that can be used to target advertising campaigns to page visitors.

You can revoke your consent at any time. You can find more information about revoking your consent either with the consent itself or at the end of this privacy policy.

For more information on the handling of transmitted data, please refer to the provider's privacy policy at www.facebook.com/about/privacy.

The provider also offers an opt-out option at www.facebook.com/about/privacy.

Facebook Conversion API

We have Facebook Conversion API for more targeted communication measures
integrated into this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also sent to the USA and transferred to other third countries.

Facebook Conversion API allows us to monitor the interactions of the
website visitors with our website and send them to Facebook to pass on information in order to improve advertising performance on Facebook.

In particular, the time of access, the website accessed, your IP address and your user agent and, if applicable, other specific data (e.g. products purchased, shopping cart value and currency) are recorded. A complete overview of the data that can be collected can be found here:
https://developers.facebook.com/docs/marketing-api/conversions-api/parameters.

The use of this service is based on your consent in connection with Article 6 Paragraph 1 Letter a) GDPR and Section 25 Paragraph 1 TTDSG. You can have your consent be revoked at any time.

As far as personal data is collected with the help of the Facebook Conversion API on our website and forwarded, us and Facebook Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Article 26 GDPR). The joint responsibility is limited exclusively to the collection of data and its transfer to Facebook. The one after the forwarding processing by Facebook is not part of the shared responsibility. The obligations we share were recorded in a joint processing agreement. The text of the agreement can be found at:
https://www.facebook.com/legal/controller_addendum.
According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for the data protection-safe implementation of the tool on our website. For the data security of Facebook products, it is Facebooks responsibility. Rights of those affected (for example
You can submit requests for information regarding the data processed by Facebook directly to Facebook. If you assert your data subject rights with us, we are obliged to forward these to Facebook. You can find further information on protecting your privacy in Facebook's data protection information: https://de-de.facebook.com/about/privacy/.

Data transfer to the USA is based on the EU Commission's standard contractual clauses. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

Facebook is certified according to the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards when data is processed in the USA. Every DPF certified company undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-
search/participant-detail?contact=true&id=a2zt0000000GnywAAC&status=Active.


DoubleClick

As part of the application of Google Analytics, this website uses the DoubleClick web analytics service, which enables recognition of the user's browser when visiting other websites. The data collected is only evaluated for statistical purposes and in anonymous form. The information generated by the cookie about our website will be transmitted to and stored by Google on servers in the United States. The IP address is shortened before transmission within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area by activating IP anonymization.

Only in exceptional cases will the IP address be transferred in full to a Google server in the USA before being shortened there. The anonymized IP address transmitted by the user's browser as part of Google Analytics is not merged with other Google data. DoubleClick cookies do not contain any personal data.

The information generated is used to compile reports on the activities on this website and to provide other services related to the use of this website. If required by law, Google may transfer this information to third parties or to the extent that third parties process this data on Google's behalf.

The legal basis of any processing of personal data is the consent of the user in accordance with Art. 6 para. 1 lit. a GDPR. The user has the option at any time to object to the tracking web analysis for the future or to deactivate the DoubleClick cookie. The browser extension required for this can be downloaded and installed on the corresponding Google website. If several end devices or browsers are used by the user, the opt-out must be performed for each end device or browser. For this purpose, the user can click on the following link: http://google.com/ads/preferences/html/opt-out.html

Sleeknote 

In order to provide user-friendly access to specific content (such as downloads, feedback options, and registration for newsletters and promotions) that is appropriate to your use of our website and quick, we use the Sleeknote service on this website if you consent to it. This service is operated by Sleeknote ApS, Jens Baggesens Vej 90A, 8200 Aarhus, Denmark ("Sleeknote").

Through the Sleeknote service, certain additional content is displayed to you as a visitor, depending on which content of our website you call up and how you use our website, in order to make your visit as pleasant and efficient as possible for you. In this context, Sleeknote collects and stores data on the use of our website, from which user profiles are created using pseudonyms, in order to evaluate the acceptance of the displayed content and to be able to continuously improve and display the individual displayed contents in an optimized manner based on user needs. For this purpose, the Sleeknote service also sets cookies on your computer. These are small text files that are stored locally on your computer. The cookies remain stored on your computer for a maximum of 2 years. The pseudonymized usage profiles are not merged with other personal data without the explicit consent of the person concerned. Your personal data will also not be passed on to third parties. Sleeknote generally stores the data collected via the Sleeknote service for up to 3 months and then deletes it.

We have concluded an order processing contract with Sleeknote. The transfer of personal data concerning you is therefore based on Art. 28 GDPR.

For more information about Sleeknote's protection of your personal data, please also see Sleeknote's privacy notice: https://sleeknote.com/privacy-policy.

We use the Sleeknote service with your consent. The legal basis for the use of the Sleeknote service is therefore Art. 6 para. 1 p. 1 lit. a) GDPR in conjunction with § 25 TTDSG.

§ 8 Social networks 

Facebook

This section applies to our processing of personal data via our Facebook presence: Meta Platforms Ireland Limited Facebook Ireland Limited ("Facebook") is generally responsible for the collection and further processing of personal user data on Facebook websites. Please note that Facebook collects and processes certain information about your visit to our Facebook page even if you do not have a Facebook user account or are not logged in to Facebook. For information on the processing of personal data by Facebook, please refer to Facebook's data policy (Privacy Policy): https://www.facebook.com/about/privacy/

For us as the operator of this Facebook page, only your public profile on Facebook is visible. Which information is visible here depends on your settings in your profile. In addition, we process your personal data (such as your name and the content of your messages, inquiries or other contributions to us) when you contact us via our Facebook page or when you publish content via our Facebook presence, e.g. in the form of a comment. We then process this data for the purpose of processing your contributions accordingly and, if necessary, responding to them. These purposes also include our legitimate interests within the meaning of the legal basis of Art. 6 (1) f) of the European Data Protection Regulation (GDPR).

We store your personal data on our systems, i.e. outside of Facebook, if and as long as it is required for the purposes of collection or if there are legal retention obligations. The regulations of the Page Insights supplement apply to our contractual relationship with Facebook, which provides for and regulates joint responsibility for data processing via Facebook: https://www.facebook.com/legal/terms/page_controller_addendum

Instagram

This privacy policy applies to our Instagram presence:

Instagram is part of the Facebook group of companies and shares infrastructure, systems, and technology with Facebook and with other Facebook companies https://www.facebook.com/help/111814505650678?ref=dp).

We expressly point out that Facebook stores the data of the users of its services (e.g. personal information, IP address, etc.) and may also use them for business purposes. For more information on Facebook's data processing on Instagram, please refer to Instagram's privacy policy at https://help.instagram.com/519522125107875?helpref=page_content.

We have no influence on the data collection and further processing by Facebook/Instagram. Furthermore, it is not recognizable for us to what extent, at which location and for how long the data is stored, to what extent Facebook/Instagram complies with existing deletion obligations, which evaluations and links are made with the data and to whom the data is passed on. Insofar as personal data are processed in connection with our Instagram page and Facebook alone decides on the purposes and means of the processing

Meta Platforms Ireland Limited Facebook Ireland Limited (also: "Facebook/Instagram"), 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, sole controller.

Contacting the company data protection officer for Instagram is possible at the following address: https://www.facebook.com/help/contact/540977946302970 provided contact form. The Instagram Privacy Policy (http://instagram.com/legal/privacy/) identifies the categories of personal data processed when using Facebook products (https://www.facebook.com/help/1561485474074139?ref=dp), describes in general terms the purposes for which this data is used, and identifies the categories of recipients to whom this data may be disclosed. The Data Policy also provides information on the legal basis for the processing of this data and information on how to withdraw consent you have given regarding the processing of personal data. Further information on the respective legal basis can be found at https://www.facebook.com/about/privacy/legal_bases.

In the Data Policy you will also find information on how to exercise your rights of access, rectification, portability and erasure against Facebook. Under this point you will also find information about your right to object to certain processing of personal data. You can find more information about your control options here: https://www.facebook.com/help/2069235856423257. In the Data Policy, you will also find information about the duration for which personal data is stored and information about the criteria regarding the determination of this duration and the possibility of blocking or deleting Instagram accounts. The Data Policy refers to Facebook/Instagram's intention to transfer data to third countries, if applicable. Please note that if personal data is processed in the United States of America, the level of protection for your data may be lower than if it is processed within the EU.

When you visit our Instagram page and your browser allows cookies to be stored, Facebook/Instagram stores information in the form of small text files in your browser's memory (hereinafter "cookies") and can access this information when you visit the Instagram platform or a website that embeds Instagram technologies. You can find more information about the purpose of the cookies used, the integration of these cookies by other websites and your control options in this regard here: https://help.instagram.com/1896641480634370?ref=ig.

Cookies enable Instagram/Facebook to track your user behavior (across devices for registered users) even beyond the Instagram platform on other websites and also to build profiles on your behavior. This applies both to persons registered with the Instagram platform and to persons not registered there. If you want to avoid such traceability of your behavior, you should log out of Facebook or Instagram or deactivate the "stay logged in" function, delete the cookies on your device and close and restart your browser.

In addition to the content you submit, information about your profile, likes, and posts is visible to us depending on your privacy settings. You can learn how to change your privacy settings here: https://de-de.facebook.com/help/instagram/116024195217477.

The processing of your personal data when contacting or interacting with us via our Instagram presence is carried out by us on the basis of Art. 6 (1) p. 1 lit. f GDPR. Our legitimate interest within the meaning of the legal basis is to respond to your request and to communicate with you appropriately and for the intended purpose. If your contact is aimed at the conclusion of a contract (for example, in the context of participation in competitions), the additional legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b GDPR.

LinkedIn

We use the "LinkedIn" platform for the purpose of presenting our company and our bootcamps and other products there and to draw your attention to current trends, products and services from us via posts and videos and also with advertising media such as banners and sponsored links/sponsored posts. The following information also serves as privacy notice for our online presence there. 

The services for the EU are provided by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland. The headquarters of LinkedIn Inc. is located in Sunnyvale, California, USA. The company belongs to Microsoft.

A hyperlink to LinkedIn is integrated within our website and identified by a logo. After clicking on the logo, the LinkedIn website opens in a new tab of the browser. 

When you access LinkedIn services, LinkedIn may receive personal information from you. For details, please see LinkedIn's privacy policy at the following link:

https://www.linkedin.com/ legal/privacy-policy   

LinkedIn's cookie policy can be found at the following link: 

https://www.linkedin.com/ legal/cookie-policy

As part of the maintenance of our company profile and the implementation of our LinkedIn advertising campaigns, we have limited access to statistical evaluations from LinkedIn, e.g., about the number of page views of our online presence. LinkedIn provides this data in aggregated and anonymized form for certain periods of time, but does not allow any conclusions to be drawn about identifiable visitors to our company page. 

We have no influence on the means and purposes of the processing of personal data by LinkedIn, insofar as this is collected in connection with a visit to the LinkedIn website and our LinkedIn online presence. We would like to point out that you use LinkedIn and its functions on your own responsibility. In the event that we process your personal data, this is done on the basis of our legitimate interest (Art. 6 (1) (f) GDPR), as we assume that your fundamental rights to the protection of your personal data do not prevail here. 

The legal basis for the processing of your data in connection with the use of our company presence and our LinkedIn campaigns is Art.6 para.1 p.1 lit. f GDPR in connection with our legitimate interests in expanding the base of our customers and interested parties and also potential employees as well as, insofar as your consent has been given, Art. 6 para. 1 lit. A GDPR. If we communicate with you via linkedin and the communication serves the preparation or implementation of a contractual relationship with you, the legal basis is Art. 6 (1) lit. b GDPR. We store your activities and personal data published via our company website until you revoke your consent. In addition, we comply with the statutory retention periods. 


According to LinkedIn, the data centers for your members (who, like us, are registered with LinkedIn and have an account) are located in the USA. The USA may have lower requirements for lawful processing of personal data than within the EU. The LinkedIn services make it necessary for data to be transferred from the European Union (EU), to the United States of America (USA) and back. This also affects you as a visitor, insofar as you use services and certain functions of LinkedIn, e.g. when you make a comment on a post by us.

The data transfer to the USA is based on standard contractual clauses. You can find information from LinkedIn on this under the following links: 

https://www.linkedin.com/help/ linkedin/answer/62533?trk= microsites-frontend_legal_ privacy-policy&lang=en https://de.linkedin.com/legal/ l/dpa 

LinkedIn's user agreement (applicable to members and visitors) can be found at the following link:

https://de.linkedin.com/ legal/user-agreement.


Target group oriented advertising

We also occasionally use the social media platforms described to play out targeted advertising.

For this purpose, we use target group definitions that are provided to us by the social media provider. We only use anonymous target group definitions - that is, we define characteristics based on, for example, general demographic information, behavior, interests and connections. The operator of the social media platform uses these to play out advertisements to its users accordingly. The legal basis for this is the consent that the operator of the social media platform has obtained from its users. If you wish to revoke this consent, please use the revocation options provided by the provider of the social media platform, as the social media platform operator is responsible for this processing. Occasionally, we or the provider of the social media platform also use publicly available data for target group definition. The legal basis for this processing, if you have given your consent, is Art. 6 (1) a GDPR or, if permissible and relevant, Art. 6 (1) f GDPR in conjunction with our legitimate interest in advertising that corresponds as closely as possible to the target group. 

We do not use target group definition based on location data. We do not pass on any personal data to the operator of the social media platform as part of the target group definition. 

Occasionally, we also use information about visits to or interaction with other sites (so-called remarketing) to define target groups. For this purpose, we also use cookies, among other things. In these cases, however, we obtain the consent of the user in advance via a consent banner on the respective other pages and provide information about the data processing at this point. You can revoke this consent at any time by calling up the consent banner of the corresponding website again.


§ 9 Newsletter and email messages

(1) With your consent, you can subscribe to our newsletter (if offered), with which we inform you about our current interesting offers. The advertised services and benefits are named in the declaration of consent.

(2) For the registration to our newsletter we use the so-called double-opt-in procedure. This means that after your registration, we will send you an email to the email address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

(3) The only mandatory information for sending the newsletter is your e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After your confirmation, we store your e-mail address for the purpose of sending the newsletter. The legal basis is Art. 6 para. 1 p. 1 lit. a GDPR.

(4) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter email or by sending a message to the contact details provided in the imprint.

(5) We would like to point out that we can evaluate your user behavior when sending the newsletter. For this evaluation, the sent emails then contain so-called web beacons or tracking pixels, which are single-pixel image files that are stored on our website. For the evaluations, we link the data mentioned in § 3 and the web beacons with your e-mail address and an individual ID. Links received in the newsletter also contain this ID. With the data obtained in this way, we create a user profile in order to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click on in them and infer your personal interests from this. We link this data to actions you have taken on our website. 

You can object to this tracking at any time by clicking on the separate link provided in each email or by informing us via another contact channel. The information is stored for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously. Moreover, such tracking is not possible if you have deactivated the display of images by default in your e-mail program. In this case, the newsletter will not be fully displayed to you and you may not be able to use all functions. If you display the images manually, the above-mentioned tracking will take place.

(6) We use your email address, which we received as part of the sale of our services, to electronically send advertising for our own goods or services that are similar to those that you have already purchased from us, unless you object to this use have. Providing the email address is necessary for the conclusion of the contract. Failure to provide it will result in no contract being concluded. The processing is carried out on the basis of Art. 6 (1) lit. f GDPR for the legitimate interest in direct advertising. Legal basis for using your email address for advertising for your own similar products is Section 7 Paragraph 3 UWG. You can object to the use of your email address at any time by notifying us using our contact details above or by using the unsubscribe function provided in every promotional email from us contradict. There are no costs for this other than the transmission costs according to the basic tariffs of the means of communication you use.

(7) The dispatch of the newsletter and other emails from the communication flow initiated via the forms on our website is carried out using "MailChimp", a messaging platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. In this context, e-mail transmission data and personal data contained therein may also be processed in the USA, because transmission service providers from there are involved in e-mail transmission. The general conditions for the processing of personal data in the USA differ from the European level of data protection. There is no adequacy decision by the European Commission for the USA that establishes an equivalent level of data protection. We have therefore concluded European standard contractual clauses with all service providers located in the USA. You can view the privacy policy of MailChimp here.

The newsletter and other emails from the communication flow, which is initiated via the forms on our website, are sent using “Mailmodo”, a message delivery platform from the US provider Mailmodo Technologies Inc., 16192, Coastal Highway, Lewes, Delaware, 19958, USA. In this context, the e-mail sending data and the personal data contained therein may also be processed in the USA and India because shipping service providers from there participate in sending e-mails. The framework conditions for the processing of personal data in the USA and India differ from the European level of data protection. We have therefore concluded European standard contractual clauses with Mailmodo (https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=CELEX:32021D0914&from=DE). You can view Mailmodo's privacy policy here.

(8) The email addresses of our newsletter recipients, as well as their other data described in the context of this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, MailChimp may use this data to optimize or improve its own services, e.g. to technically optimize the dispatch and display of the newsletters or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.

The email addresses of our newsletter recipients, as well as their other data described in this information, are stored on Mailmodo's servers in the USA. Mialmodo uses this information to send and evaluate the newsletters on our behalf. Mailmodo does not use the data of our newsletter recipients to write to them ourselves or to pass them on to third parties.

§ 10 Linked content / sharing functions

Our website contains links to third-party websites. The respective data protection declarations and data protection notices of the respective operators of the linked websites apply. We point out that we are not responsible for the data processing practices on third-party platforms outside our own sphere of influence.

 § 11 Data protection during applications and the application process/assessment

The data controller collects and processes the personal data of applicants for the purpose of handling the application process and assessment. Concerns, on the one hand, applications related to employment and other activities for the responsible party and, on the other hand, the application for the study programs, workshops and bootcamps offered by the responsible party. 

The processing of personal data within the scope of the application procedure is in any case usually carried out electronically. 

The following applies to employment relationships and other activities for the person responsible: If the person responsible concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the person responsible does not conclude an employment contract with the applicant, the application documents are automatically deleted four months after notification of the rejection decision, provided that no other legitimate interests of the person responsible oppose deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG). The legal basis for the processing of personal data of applicants is Art. 6 para. 1 lit. b, 88 GDPR, in conjunction with Section 26 of the Federal Data Protection Act (BDSG), furthermore, insofar as the processing is carried out to meet legal requirements, Art. 6. para. 1 lit. c GDPR and, insofar as consent of the data subject is the basis of the processing, Art. 6 para. 1 lit. a GDPR in conjunction with Section 26 BDSG.

For study programs, workshops and bootcamps, the following applies: if the application is successful, a contractual relationship is established regarding the services of the responsible party for the respective applicant and the consideration to be provided by the respective applicant. The personal data processed in this context will be stored for the duration of the contractual relationship and beyond that until the expiry of the regular statutory limitation periods, unless legal obligations, in particular tax and commercial law retention obligations, require longer storage. 

If the application is not successful, the personal data will be deleted after a period of four months. With the separately obtained consent of the data subject, the data may be stored for a further twelve months so that the application can be considered again in the event of a vacancy for a course or any offers that may be considered for the applicant.

The legal basis of the processing is Art. 6 (1) lit. b GDPR, insofar as the processing is carried out for the purpose of initiating, implementing and settling the contractual relationship, Art. 6 (1) lit. f GDPR, insofar as the legitimate interests of the controller in proper documentation of its business transactions, in providing evidence in the context of any disputes and in the management, maintenance and expansion of the business relationship between the controller and its contractual partner, and via this Art. 6 (1) lit. c GDPR, insofar as the processing is carried out to comply with statutory provisions. If the processing is based on the consent of the data subject, Art. 6(1)(a) GDPR is the legal basis of the processing.

We also reserve the right to use master data (email address and telephone number) provided in pseudonymized form as part of the application process for our study programs and boot camps in order to make online advertising measures more targeted and interesting for the respective potential or existing contractual partner to play out. Under no circumstances will we provide or pass on such contact details to third parties in a readable, unencrypted form. Our legitimate interests within the meaning of the legal basis of Article 6 Paragraph 1 Letter f are the aforementioned purposes of optimizing our advertising and information measures and increasing the quality of communication GDPR, unless the processing is based on the consent of the data subjects in conjunction with Article 6 Paragraph 1 lit. a) GDPR.

For application procedures, we use the services and performance of Teamtailor AB, Östgötagatan 16. SE-116 25 Stockholm, which provides platform services on our behalf for the administration and implementation of application procedures, whereby personal data is processed exclusively in the European Union.

§ 12 Service provider

In some cases, we use external service providers (processors) to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly monitored.

If our service providers or partners are located in a country outside the European Economic Area and the (EEA), we will inform you about the consequences of this circumstance in the description of the offer.

§ 13 Deletion

Unless otherwise specified in the respective individual information, the controller processes personal data in accordance with the statutory provisions for the purposes presented here in each case and only for as long as personal identification of the data subject is required for the respective purpose. Subsequently, the data is deleted or neutralized/anonymized in accordance with data protection.


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