Privacy Policy

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offering").

The terms used are not gender-specific.

Last updated: 1 July 2026

TABLE OF CONTENTS

Preamble

Controller

Overview of Processing Activities

Applicable Legal Bases

Security Measures

Transmission of Personal Data

International Data Transfers

General Information on Data Storage and Deletion

Rights of Data Subjects

Provision of the Online Offering and Web Hosting

Use of Cookies

Blogs and Publication Media

Contact and Enquiry Management

Newsletter and Electronic Notifications

Web Analytics, Monitoring, and Optimisation

Online Marketing

Affiliate Programmes and Affiliate Links

Presences in Social Networks (Social Media)

Plug-ins and Embedded Functions and Content

Management, Organisation, and Support Tools

Amendments and Updates

Definitions

CONTROLLER

Manasi Gopalakrishnan/Food for Normal People

Im Mediapark 5b

50670 Köln, Germany

Email address: mgfoodie@gmail.comfirstname.lastname@exampledomain.eu

OVERVIEW OF PROCESSING ACTIVITIES

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

Types of data processed:

- Inventory data

- Employee data

- Contact data

- Content data

- Contract data

- Usage data

- Meta, communication, and procedural data

- Event data (Facebook)

- Log data

Categories of data subjects:

- Service recipients and clients

- Employees

- Prospective customers

- Communication partners

- Users

- Third parties

- Whistleblowers

Purposes of processing:

- Provision of contractual services and fulfilment of contractual obligations

- Communication

- Security measures

- Direct marketing

- Reach measurement

- Tracking

- Office and organisational procedures

- Audience building

- Affiliate tracking

- Organisational and administrative procedures

- Feedback

- Marketing

- Profiles with user-related information

- Provision of our online offering and user-friendliness

- Information technology infrastructure

- Whistleblower protection

- Public relations

APPLICABLE LEGAL BASES

Applicable legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

- Consent (Art. 6(1)(a) GDPR): The data subject has given consent to the processing of their personal data for one or more specific purposes.

- Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

- Legal obligation (Art. 6(1)(c) GDPR): Processing is necessary for compliance with a legal obligation to which the controller is subject.

- Legitimate interests (Art. 6(1)(f) GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The BDSG contains specific provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states may also apply.

Note on the applicability of the GDPR and the Swiss DPA: These data protection notices serve to provide information under both the Swiss Data Protection Act (DPA) and the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA, such as "processing" of "personal data," "overriding interest," and "particularly sensitive personal data," the terms used in the GDPR, namely "processing" of "personal data," "legitimate interest," and "special categories of data," are used. However, the legal meaning of these terms continues to be determined under the Swiss DPA within its scope of application.

Applicability of data protection regulations in the country of domicile: In the country in which the controller is domiciled, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

SECURITY MEASURES

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

These measures include in particular safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, disclosure, assurance of availability, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account from the outset in the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

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

TRANSMISSION OF PERSONAL DATA

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

INTERNATIONAL DATA TRANSFERS

Data processing in third countries: Where we transmit data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the context of using third-party services or the disclosure or transmission of data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or when the privacy policy explicitly refers to data transfers to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a safe legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur within the framework of the DPF, the Standard Contractual Clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of political or legal changes.

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

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

GENERAL INFORMATION ON DATA STORAGE AND DELETION

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

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

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

Where there are multiple entries regarding the retention period or deletion deadlines for a particular item of data, the longest period shall always prevail. Data that is no longer stored for the originally intended purpose but is retained due to legal requirements or other reasons shall be processed exclusively for the reasons that justify its retention.

Commencement of deadlines at the end of the year: Where a deadline does not expressly begin on a specific date and amounts to at least one year, it shall automatically commence at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the termination or other ending of the legal relationship takes effect.

RIGHTS OF DATA SUBJECTS

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

- Right to withdraw consent: You have the right to withdraw any consent given at any time.

- Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed and to obtain access to such data, as well as further information and a copy of the data, in accordance with legal requirements.

- Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.

- Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be erased without undue delay, or alternatively to request restriction of the processing of such data in accordance with legal requirements.

- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, in accordance with legal requirements, or to request its transmission to another controller.

- Complaint to 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, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

PROVISION OF THE ONLINE OFFERING AND WEB HOSTING

We process the data of users in order to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to deliver the content and functions of our online services to the user's browser or device.

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

- Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." Server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally resolved.

USE OF COOKIES

The term "cookies" refers to functions that store and read information on users' devices. Cookies may also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal requirements. To this end, we obtain the prior consent of users where required. If consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is indispensable for providing expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent may be revoked at any time. We clearly inform users about the scope and which cookies are used.

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

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

- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).

- Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Similarly, user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), they should assume that cookies are permanent and that the storage duration can be up to two years.

General notes on revocation and objection (opt-out): Users may revoke consent they have given at any time and also file an objection to processing in accordance with legal requirements, including through the privacy settings of their browser.

- Data types processed: Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

- Data subjects: Users (e.g. website visitors, users of online services).

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further information on processing operations, procedures, and services:

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

BLOGS AND PUBLICATION MEDIA

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only insofar as this is necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within this privacy policy.

- Data types processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Feedback (e.g. collecting feedback via online forms); Provision of our online offering and user-friendliness; Security measures. Organisational and administrative procedures.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

- Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and contributions (insults, prohibited political propaganda, etc.). In such cases, we ourselves may be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, on the basis of our legitimate interests, we reserve the right to process users' information for the purpose of spam detection. On the same legal basis, in the case of surveys, we reserve the right to store users' IP addresses for their duration and to use cookies to prevent multiple voting. The information provided in the context of comments and contributions regarding the person, any contact and website information, as well as the content-related information, is permanently stored by us until the user objects; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

CONTACT AND ENQUIRY MANAGEMENT

When contacting us (e.g. by post, contact form, email, telephone, or via social media) and within the framework of existing user and business relationships, the information of the enquiring persons is processed insofar as this is necessary for responding to the contact enquiries and any requested measures.

- Data types processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation). Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

- Data subjects: Communication partners.

- Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via online forms). Provision of our online offering and user-friendliness.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing operations, procedures, and services:

- Contact form: When contacting us via our contact form, by email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and processing the respective enquiry. This typically includes details such as name, contact information, and, where applicable, further information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

NEWSLETTER AND ELECTRONIC NOTIFICATIONS

We send newsletters, emails, and other electronic notifications (hereinafter "Newsletter") exclusively with the consent of the recipients or on a legal basis. Where the contents of the newsletter are described in the context of registration, these contents are decisive for the user's consent. To subscribe to our newsletter, it is normally sufficient to provide your email address. However, in order to offer you a personalised service, we may ask for your name for personal address in the newsletter or for further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a potential defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving its proper conduct. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents: Information about us, our services, promotions, and offers.

- Data types processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

- Data subjects: Communication partners.

- Purposes of processing and legitimate interests: Direct marketing (e.g. by email or post).

- Legal bases: Consent (Art. 6(1)(a) GDPR).

- Right to object (opt-out): You may cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you may use one of the contact options listed above, preferably email, for this purpose.

Further information on processing operations, procedures, and services:

- Measurement of open and click rates: The newsletters contain a so-called "web beacon," i.e. a pixel-sized file that is retrieved from our server (or, if we use a mailing service provider, from their server) when the newsletter is opened. In the course of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval. This information is used for the technical improvement of our newsletter based on technical data or the target groups and their reading behaviour based on their retrieval locations (which [This text section must be unlocked with a Premium Licence]); Legal bases: Consent (Art. 6(1)(a) GDPR).

WEB ANALYTICS, MONITORING, AND OPTIMISATION

Web analytics (also referred to as "reach measurement") serves to evaluate visitor flows to our online offering and may encompass behaviour, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used, or invite re-use. We can also determine which areas require optimisation.

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

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and then read from it. The information collected includes in particular websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. Where users have consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, users' IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. In general, in the context of web analytics, A/B testing, and optimisation, no clear data of users (such as email addresses or names) is stored, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, detection of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion." Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).

- Security measures: IP masking (pseudonymisation of the IP address).

- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

- Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analytics information to a device in order to identify which content users have accessed within one or more usage sessions, which search terms they have used, which content they have accessed again, or which content they have interacted with in our online offering. The time of use and its duration are also stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers.

Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides approximate geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based equivalents). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://business.safety.google/privacy/; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

ONLINE MARKETING

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

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

In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e. pseudonymisation by truncating the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored within the framework of online marketing procedures, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles.

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

In exceptional cases, it is possible to assign clear data to the profiles, primarily when the users are, for example, members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving consent during registration.

In principle, we only receive access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures has led to a so-called conversion, i.e. for example to the conclusion of a contract with us. Conversion measurement is used solely for the success analysis of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

Notes on revocation and objection:

We refer to the data protection notices of the respective providers and the objection options (so-called "opt-out") stated for the providers. Where no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered in summary for the respective areas:

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

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

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

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

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, detection of returning visitors); Tracking (e.g. interest/behaviour-based profiling, use of cookies); Audience building; Marketing. Profiles with user-related information (creation of user profiles).

- Security measures: IP masking (pseudonymisation of the IP address).

AFFILIATE PROGRAMMES AND AFFILIATE LINKS

We integrate so-called affiliate links or other references (which may include, for example, search masks, widgets, or discount codes) to the offerings and services of third-party providers into our online offering (collectively referred to as "affiliate links"). When users follow the affiliate links or subsequently take up the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

In order to be able to track whether users have taken up the offers of an affiliate link used by us, it is necessary for the respective third-party providers to be informed that the users have followed an affiliate link used within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves solely the purpose of commission accounting and is cancelled as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links may be supplemented by certain values that form part of the link or may be stored elsewhere, e.g. in a cookie. These values may include in particular the originating website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

- Data types processed: Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

- Data subjects: Prospective customers. Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Affiliate tracking.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

- Agoda.com partner programme: Affiliate marketing partner programme; Service provider: Agoda Company Pte. Ltd., 30 Cecil Street Prudential Tower #19-08, Singapore 049712; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.agoda.com/de-de. Privacy policy: https://www.agoda.com/de-de/info/agoda-privacy.html.

- Amazon Associates Programme: Affiliate partner programme (Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or its affiliates); Service provider: Amazon EU S.a r.l. (Societe a responsabilite limitee), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.amazon.de; Privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010. Basis for third-country transfers: Data Privacy Framework (DPF).

- Digistore24 partner programme: Affiliate marketing partner programme; Service provider: Digistore24 GmbH, St.-Godehard-Strasse 32, 31139 Hildesheim, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.digistore24.com. Privacy policy: https://www.digistore24.com/page/privacy.

PRESENCES IN SOCIAL NETWORKS (SOCIAL MEDIA)

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

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

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on the usage behaviour and resulting interests of users. These usage profiles may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by the users (particularly if the users are members of the respective platforms and are logged in there).

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

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data in each case and can directly take appropriate measures and provide information. Should you nevertheless need assistance, you are welcome to contact us.

- Data types processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online forms). Public relations.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

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

- Facebook Pages: Profiles within the social network Facebook. The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook Page ("Fan Page"). This includes in particular information about user behaviour (e.g. content viewed or interacted with, actions taken) and device information (e.g. IP address, operating system, browser type, language settings, cookie data). Further details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook uses this data to provide us with statistical evaluations via the "Page Insights" service, which provide information about how people interact with our page and its content. The basis for this is an agreement with Facebook ("Information about Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users may therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular the right of access, erasure, objection, and complaint to a supervisory authority) are not restricted by these agreements. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). For further processing, including any transmission to Meta Platforms Inc. in the USA, Meta Platforms Ireland Limited is solely responsible; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).

PLUG-INS AND EMBEDDED FUNCTIONS AND CONTENT

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or city maps (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the users, as without the IP address they could not send the content to their browsers. The IP address is therefore required for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Through the "pixel tags," information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, visit times, and further information about the use of our online offering, as well as be linked with such information from other sources.

- Data types processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Event data (Facebook) ("Event data" is information that is sent, for example, via Meta Pixel (whether via apps or other channels) to the provider Meta and relates to persons or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations, and product purchases. The processing of event data is carried out with the aim of creating target groups for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as written comments, no login information, and no contact information such as names, email addresses, or telephone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target groups formed from it disappear with the deletion of our Meta user accounts).

- Data subjects: Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; Reach measurement (e.g. access statistics, detection of returning visitors); Tracking (e.g. interest/behaviour-based profiling, use of cookies); Audience building; Marketing. Profiles with user-related information (creation of user profiles).

- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures, and services:

- Facebook plugins and content: Facebook Social Plugins and content. These may include, for example, content such as images, videos, or texts and buttons that allow users to share content of this online offering within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/. We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects by means of the Facebook Social Plugins (and embedding functions for content) that are executed on our online offering or receives in the context of a transmission for the following purposes: a) display of content and advertising information that presumably corresponds to the interests of the users; b) delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improvement of ad delivery and personalisation of functions and content (e.g. improvement of the detection of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Controller Addendum," https://www.facebook.com/legal/controller_addendum), which regulates in particular the security measures that Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil data subject rights (i.e. users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e. do not contain information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility but on the basis of a data processing agreement ("Data Processing Terms," https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms), and with regard to processing in the USA on the basis of Standard Contractual Clauses ("Facebook EU Data Transfer Addendum," https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular the right of access, erasure, objection, and complaint to a competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).

- Instagram plugins and content: Instagram Plugins and content. These may include, for example, content such as images, videos, or texts and buttons that allow users to share content of this online offering within Instagram. We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects by means of Instagram functions (e.g. embedding functions for content) that are executed on our online offering or receives in the context of a transmission for the following purposes: a) display of content and advertising information that presumably corresponds to the interests of the users; b) delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improvement of ad delivery and personalisation of functions and content (e.g. improvement of the detection of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Controller Addendum," https://www.facebook.com/legal/controller_addendum), which regulates in particular the security measures that Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil data subject rights (i.e. users can, for example, direct requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e. do not contain information about individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility but on the basis of a data processing agreement ("Data Processing Terms," https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms), and with regard to processing in the USA on the basis of Standard Contractual Clauses ("Facebook EU Data Transfer Addendum," https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular the right of access, erasure, objection, and complaint to a competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.

- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.youtube.com; Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.

MANAGEMENT, ORGANISATION, AND SUPPORT TOOLS

We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organisation, administration, planning, and provision of our services. When selecting third-party providers and their services, we comply with legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on transactions, contracts, other processes, and their content.

Where users are referred to the third-party providers or their software or platforms in the course of communication, business, or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation, or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

- Data types processed: Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

- Data subjects: Communication partners. Users (e.g. website visitors, users of online services).

- Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.

- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion."

- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

AMENDMENTS AND UPDATES

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

Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the information before contacting them.

DEFINITIONS

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

- Affiliate tracking: In the context of affiliate tracking, links by means of which the linking websites refer users to websites with product or other offerings are logged. The operators of the respective linking websites may receive a commission when users follow these so-called affiliate links and subsequently take up the offerings (e.g. purchase goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offerings subsequently take them up as a result of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary that they be supplemented by certain values that become part of the link or are stored elsewhere, e.g. in a cookie. These values include in particular the originating website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offering, an online identifier of the user, and tracking-specific values such as advertising material ID, partner ID, and categorisations.

- Employees: Employees refer to persons who are in an employment relationship, whether as workers, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It involves the obligation of the employer to pay the employee remuneration, while the employee performs their work. The employment relationship encompasses various phases, including the establishment, in which the employment contract is concluded, the implementation, in which the employee carries out their work, and the termination, when the employment relationship ends, whether by notice of termination, termination agreement, or otherwise. Employee data comprises all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data, and performance assessments.

- Inventory data: Inventory data encompasses essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar allocations. This data may include, among other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, facilities, or systems by enabling unambiguous allocation and communication.

- Content data: Content data encompasses information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.

- Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.

- Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about the manner in which data is processed, transmitted, and managed. Meta data, also known as data about data, encompasses information that describes the context, origin, and structure of other data. It may include details about file size, creation date, author of a document, and modification histories. Communication data records the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the persons involved, timestamps, and transmission routes. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used for tracking and verifying operations.

- Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and through which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.

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

- Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, encompasses any form of automated processing of personal data that consists of using such personal data to analyse, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are frequently used for profiling purposes.

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

- Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate visitor flows to an online offering and may encompass the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.

- Tracking: "Tracking" refers to the ability to trace the behaviour of users across multiple online offerings. As a rule, behaviour and interest information is stored in cookies or on the servers of the providers of tracking technologies with regard to the online offerings used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that presumably correspond to their interests.

- Controller: "Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

- Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or deletion.

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

- Audience building: Audience building (also known as "Custom Audiences") refers to the determination of target groups for advertising purposes, e.g. the display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. "Lookalike Audiences" (or similar target groups) in turn refers to content deemed suitable being displayed to users whose profiles or interests presumably correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.

Created with the free Privacy Policy Generator by Dr. Thomas Schwenke (datenschutz-generator.de).