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+43 5287 57 755
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Hintertux 794
6293 Tux, Austria
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Privacy Policy

Preamble

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. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

As of: July 30, 2026

Generated with Datenschutz-Generator.de by Dr. Thomas Schwenke

Table of Contents

Controller

Norbert Pichlsberger
Hintertux 794
6293 Tux
Austria

Email address: office@sstt.at

Phone: +43 5287 87755

Impressum: https://sstt.at/en/imprint

Overview of Processing Operations

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

Types of Data Processed

  • Inventory data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Social data.
  • Applicant data.
  • Image and/or video recordings.
  • Audio recordings.
  • Log data.
  • Performance and behavioral data.
  • Working time data.
  • Salary data.

Special Categories of Data

  • Health data.
  • Religious or philosophical beliefs.
  • Trade union membership.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Interested parties.
  • Communication partners.
  • Users.
  • Applicants.
  • Sweepstakes and contest participants.
  • Business and contractual partners.
  • Education and course participants.
  • Participants.
  • Depicted persons.
  • Third parties.
  • Whistleblowers.
  • Customers.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Application procedures.
  • Conducting sweepstakes and contests.
  • Feedback.
  • Surveys and questionnaires.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Establishment and execution of employment relationships.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Financial and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and operational procedures.
  • Artificial intelligence (AI).

Relevant Legal Bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. 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 inquiries (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.
  • Application procedures as pre-contractual or contractual relationship (Art. 6(1)(b) GDPR) – If special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure so that the controller or the data subject can exercise the rights to which they are entitled under employment law and the law of social security and social protection and fulfill their obligations in this regard, their processing is carried out in accordance with Art. 9(2)(b) GDPR, in the case of the protection of vital interests of the applicants or other persons in accordance with Art. 9(2)(c) GDPR, or for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnostics, the provision of care or treatment in the health or social sector, or for the management of systems and services in the health or social sector in accordance with Art. 9(2)(h) GDPR. In the case of a voluntary disclosure of special categories of data, their processing is based on Art. 9(2)(a) GDPR.
  • Processing of special categories of personal data in relation to health, profession, and social security (Art. 9(2)(h) GDPR) – Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment, or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional.

National data protection regulations in Austria: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. This includes in particular the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains special provisions on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases.

Relevant legal bases under the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss DPA”). Unlike the GDPR, for example, the Swiss DPA does not generally require that a legal basis for the processing of personal data be stated and that the processing of personal data be carried out in good faith, lawfully, and proportionately (Art. 6(1) and (2) of the Swiss DPA). In addition, personal data is only collected by us for a specific purpose that is recognizable to the data subject and is only processed in a manner that is compatible with that purpose (Art. 6(3) of the Swiss DPA).

Note on the applicability of the GDPR and Swiss DPA: This privacy notice serves to provide information under both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, please note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA “processing” of “personal data”, “overriding interest”, and “particularly sensitive personal data”, the terms used in the GDPR “processing” of “personal data” as well as “legitimate interest” and “special categories of data” are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of the applicability of the Swiss DPA.

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

Security Measures

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

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

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users that is transmitted via our online services from unauthorized 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 that is transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

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

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business and operational interests or takes place if it is necessary to fulfill our contractual obligations or if consent from the data subjects or legal permission exists.

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies (which becomes apparent from the postal address of the respective provider or if the privacy policy expressly refers to the data transfer to third countries), this always takes place in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect 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 will act as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For 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 U.S. 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: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

Disclosure of personal data abroad: In accordance with the Swiss DPA, we only disclose personal data abroad if adequate protection of the data subjects is ensured (Art. 16 Swiss DPA). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/de/schweizerische-anerkennung-von-staaten-die-einen-angemessenen-datenschutz-gewaehrleisten), we take alternative security measures.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of Switzerland dated September 15, 2024. In addition, we have concluded standard data protection clauses with the respective providers that have been approved by the Federal Data Protection and Information Commissioner (FDPIC) and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard data protection clauses serve as additional security. Should changes occur within the framework of the DPF, the standard data protection clauses will act as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of any political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether standard data protection clauses are in place. The list of certified companies and further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, including international treaties, specific guarantees, standard data protection clauses approved by the FDPIC, or binding corporate rules previously recognized by the FDPIC or a competent data protection authority of another country.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or there are no further legal bases for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule exist if 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 legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are multiple specifications for the retention period or deletion deadlines of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons will be processed by us exclusively for the reasons justifying its retention.

Retention and deletion of data: The following general periods apply under Austrian law for the retention and archiving of personal data, insofar as this is necessary to fulfill legal obligations or to safeguard legitimate interests:

    7 years Personal data processed in connection with tax-relevant business records is retained for a period of seven years in accordance with Section 132 of the Federal Tax Code (BAO) and Sections 190–212 of the Austrian Commercial Code (UGB). This includes, in particular, books and records, annual accounts, inventories, management reports, opening balance sheets, accounting vouche

  • rs, invoices

    • , as well as commercial or business correspondence received and sent, and other documents relevant to tax collection. The period begins at the end of the calendar year for which the last entry was made and, where applicable, is extended for as long as the documents are relevant to pending tax proceedings. 3 years Data required for the assertion, exercise or defence of warranty claims, claims for damages or other contractual claims shall be retained for the d

  • uration of the applic

    • able statutory limitation period. This is generally three years in accordance with Section 1489 of the Austrian Civil Code (ABGB), provided that no longer statutory retention obligations apply.
    Translated with DeepL.com (free version)

Retention and deletion of data: The following general periods apply for retention and archiving under Swiss law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting documents and invoices, as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (OR)).
  • 10 years – Data necessary to take into account potential compensation claims or similar contractual claims and rights, as well as for processing related inquiries, based on previous business experience and customary industry practices, is stored for the period of the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 OR). Claims for rent, lease and capital interest as well as other periodic payments, from the supply of foodstuffs, for board and lodging and for debts to innkeepers, as well as from craft work, small-scale sales of goods, medical care, professional work by lawyers, legal agents, attorneys and notaries, and from the employment relationship of employees become time-barred after five years (Art. 128 OR).

Start of period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the time at which the termination or other termination of the legal relationship becomes effective.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject under the GDPR, you have various rights, which arise in particular from Art. 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 Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss DPA:

  • Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary for you to assert your rights under this Act and to ensure transparent data processing.
  • Right to data disclosure or transfer: You have the right to request the disclosure of your personal data that you have provided to us in a common electronic format.
  • Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
  • Right to object, erasure, and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers, and other cooperation partners (collectively “contractual partners”), for the initiation, execution, and processing of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures that are carried out upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfill our contractual main and ancillary obligations. This includes the provision of the agreed services, any update and information obligations, the processing of warranty and other performance disruptions, the processing of withdrawals, terminations of continuing obligations, reversals, refunds, as well as the processing of other contract-related declarations and inquiries. Both one-time contracts and ongoing contractual relationships are covered.

In particular, master data such as name, address, and, if applicable, company, contact data such as email address and telephone number, contract and service data such as contract object, contract term, order or transaction number, usage and service data, payment and billing data, as well as communication content and histories are processed. If necessary, we also process data that is disclosed or transmitted to us in the course of executing an order.

In addition, we process the data to protect our rights and to fulfill legal obligations. This includes in particular commercial and tax retention obligations, documentation obligations, and, if applicable, proof and accountability obligations. Furthermore, processing is carried out on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as in protecting our business operations and our contractual partners from misuse, endangerment of data, secrets, and other legal interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors, or other agents, insofar as this is necessary for contract performance or to fulfill legal obligations.

Personal data is only transferred to third parties if this is necessary for the fulfillment of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests, or for the fulfillment of legal obligations. We provide separate information about further processing, especially for marketing purposes, within this privacy policy.

We inform contractual partners about which data is required in individual cases during data collection, for example, in online forms through appropriate labeling or during personal contact.

Data is deleted as soon as it is no longer required for the aforementioned purposes and no legal retention obligations prevent deletion. Legal retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted within the scope of a specific order will be deleted by us after completion of the order and expiration of any retention periods, provided there are no further legal or contractual obligations for storage.

The legal basis for processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and for fulfilling the respective contractual relationship, as well as Art. 6(1)(c) GDPR for fulfilling legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Insofar as the processing is based on Art. 6(1)(f) GDPR, it is carried out to safeguard our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, enforcement and defense of legal claims, ensuring IT and data security, prevention of misuse and fraud, as well as economic management and further development of our business operations. These interests exist in particular in ensuring secure and legally compliant business operations as well as in safeguarding our entrepreneurial capacity to act.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; Interested parties; Business and contractual partners. Education and course participants.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Communication; Office and organizational procedures; Organizational and administrative procedures. Business processes and operational procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); Legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Online shop, order forms, e-commerce and service fulfilment: We process our customers’ data to enable them to select, purchase or order the chosen products, goods and related services, as well as to process payment and provide, deliver or carry out the services. Where necessary to fulfil an order, we use service providers, in particular postal, freight and shipping companies, to deliver or perform the services for our customers. To process payments, we use the services of banks and payment service providers. The required information is marked as such as part of the ordering process or a comparable purchase process and includes the details needed for delivery or provision and billing, as well as contact information so that we can contact you if necessary; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).
  • Education and training services: We process the data of participants in our education and training programmes (collectively referred to as “trainees”) in order to provide our training services to them. The data processed, the type, scope, purpose and necessity of processing are determined by the underlying contractual and training relationship. The forms of processing also include performance assessment and the evaluation of our services as well as those of the instructors. As part of our activities, we may also process special categories of data, in particular information on the trainees’ health as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. Where required, we obtain the trainees’ explicit consent and otherwise process special categories of data only if this is necessary for the provision of the training services, for the purposes of preventive health care, social protection or to protect the trainees’ vital interests; Legal basis: Contract performance and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).
  • Coaching: We process the data of our clients as well as prospective clients and other customers or contractual partners (collectively referred to as “clients”) in order to be able to provide our services to them. The processes carried out in the context of and for the purposes of coaching include: contacting and communicating with clients, needs analysis to determine suitable coaching measures, planning and conducting coaching sessions, documenting coaching progress, collecting and managing client-specific information and data, scheduling and organising appointments, providing coaching materials and resources, billing and payment management, follow-up and post-processing of coaching sessions, quality assurance and feedback processes.
    The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
    If it is necessary for the fulfilment of our contract, to protect vital interests or required by law, or if the clients have given their consent, we disclose or transfer clients’ data to third parties or agents in compliance with professional regulations, such as authorities, billing agencies and in the area of IT, office or comparable services; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).
  • Event management: We process the data of participants in events, functions and similar activities offered or organised by us (hereinafter collectively referred to as “participants” and “events”) in order to enable them to participate in the events and to use the services or activities associated with participation.

    If, in this context, we process health-related data, religious, political or other special categories of data, this is done within the scope of being made public (e.g. for topic-focused events or for health prevention, safety, or with the consent of the data subjects).

    The required information is marked as such in the context of the assignment, order or comparable conclusion of contract and includes the information required for providing the service and billing, as well as contact information in order to be able to consult as needed. To the extent that we gain access to information of end customers, employees or other persons, we process it in accordance with legal and contractual requirements; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

  • Film and television production: We process the data of our customers and clients in order to enable them to plan, produce and distribute film and television content and related services. The required information includes the details needed to carry out the project and for billing, as well as contact information for necessary coordination. To the extent that we gain access to information of end customers, actors, employees or other persons, we process it in accordance with legal and contractual requirements; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Rental services: We process the data of our tenants and prospective tenants in accordance with the underlying rental agreement. We may also process information about the characteristics and circumstances of persons or items belonging to them if this is necessary within the scope of the tenancy. This may include, for example, information about personal circumstances, movable or immovable property and financial situation, as well as the use of ancillary services (such as water or energy supply).

    Within the scope of our engagement, it may be necessary for us to process special categories of data within the meaning of Art. 9(1) GDPR, in particular information about a person’s health. The processing is carried out in order to be able to protect the tenants’ health interests and otherwise only with the tenants’ consent.

    If required for the performance of the contract or by law, or approved by the tenants, or on the basis of our legitimate interests, we disclose or transfer tenants’ data in the context of coverage enquiries, the conclusion and handling of contracts, e.g. to financial service providers, credit institutions, utility providers (e.g. electricity) or authorities.

    We also process tenants’ data if this is necessary to fulfil legal obligations (e.g. information obligations in connection with ancillary services and service charges); Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

  • Rental: Rental of sports equipment & gear; Service provider: Skischule Tuxertal Pichlsberger OG
    Hintertux 773
    6293 Tux
    Austria; Website: https://sstt.at. Privacy policy: https://sstt.at/datenschutz.

Business Processes and Procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, principals, patients or business partners, as well as other third parties – is processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as initiating business relationships. This data processing supports and facilitates business operations in areas such as customer management, sales, payment transactions, accounting and project management.

The collected data is used to fulfil contractual obligations and to organise operational processes efficiently. This includes handling business transactions, managing customer relationships, optimising sales strategies and ensuring internal accounting and financial processes. In addition, the data supports safeguarding the controller’s rights and promotes administrative tasks as well as the organisation of the company.

Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations. After statutory retention periods expire or when the purpose of processing no longer applies, the data is deleted. This also includes data that must be stored for longer due to tax law and statutory documentation obligations.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and the information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Service recipients and clients; customers; prospective customers; communication partners; business and contractual partners; third parties. 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; business processes and business management procedures; security measures; provision of our online offering and user-friendliness; communication; marketing; sales promotion; public relations; finance and payment management. IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Legal obligation (Art. 6(1) sentence 1 lit. c GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Contact management and maintenance: Procedures required in the context of organising, maintaining and securing contact information (e.g. setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact data, training employees in the effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Customer account: Customers can create an account within our online offering (e.g. customer or user account, “customer account” for short). If registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of registration as well as subsequent logins and use of the customer account, we store customers’ IP addresses along with the access times in order to be able to prove registration and prevent possible misuse of the customer account. If the customer account is cancelled, the customer account data will be deleted after the time of cancellation, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customers’ responsibility to back up their data when cancelling the customer account; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • General payment transactions: Procedures required for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debits, checking account statements, monitoring incoming and outgoing payments, chargeback management, account reconciliation, cash management); Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in accounts payable and accounts receivable (e.g. creating and checking incoming and outgoing invoices, monitoring and managing outstanding items, carrying out payment transactions, handling dunning, account reconciliation in the context of receivables and liabilities, accounts payable and accounts receivable); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Financial accounting and taxes: Procedures required for recording, managing and controlling finance-related business transactions as well as for calculating, reporting and paying taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, carrying out payment transactions, handling dunning, account reconciliation, tax advice, preparation and submission of tax returns, handling tax matters); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purchasing: Procedures required for procuring goods, raw materials or services (e.g. supplier selection and evaluation, price negotiations, placing and monitoring orders, checking and controlling deliveries, invoice verification, managing orders, inventory management, creating and maintaining purchasing guidelines); Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group definition, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Public relations: Procedures required in the context of public relations and PR (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintaining media contacts, monitoring and analysing media response, organising press conferences and public events, crisis communication, creating content for social media and company websites, managing corporate branding); Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Guest Wi-Fi: Procedures required for setting up, operating, maintaining and monitoring a wireless network for guests (e.g. installation and configuration of Wi-Fi access points, creation and management of guest access, monitoring the network connection, ensuring network security, troubleshooting connection problems, updating network software, compliance with data protection regulations); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Use of online platforms for offering and sales purposes

We offer our services on online platforms operated by other service providers. In this context, the privacy notices of the respective platforms apply in addition to our privacy notices. This applies in particular with regard to the processing of payments and the procedures used on the platforms for reach measurement and interest-based marketing.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; marketing. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Providers and services used in the course of business activities

In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and efficient operation of our business and our internal organisation.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and the information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; prospective customers. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Payment methods

Within the scope of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, use other service providers in addition to banks and credit institutions (collectively “payment service providers”). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected against unauthorised access during transmission.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount and recipient-related details. This information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account- or credit card-related information, but only information with confirmation or negative information about the payment. In some cases, the payment service providers may transmit the data to credit agencies. This transmission is for the purpose of identity and creditworthiness checks. For this, we refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and for asserting rights of withdrawal, information and other data subject rights.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Service recipients and clients. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations. Business processes and business management procedures.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Provision of the online offering and web hosting

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

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Log data (e.g., log files concerning logins or data retrieval or access times).
  • 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 equipment (computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion according to the information in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a “web host”); Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, amounts of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and also to ensure server utilisation and stability; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
  • ALL-INKL: Services in the field of providing IT infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: ALL-INKL.COM – Neue Medien Münnich, owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://all-inkl.com/; Privacy policy: https://all-inkl.com/datenschutzinformationen/. Data processing agreement: Provided by the service provider.
  • WP Rocket: Caching and load optimisation – functions that serve to store certain website content so it can be loaded faster on repeat visits. This reduces loading times and improves the user experience; Service provider: SAS WP MEDIA, address: 4 rue de la République, 69001 LYON, France; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://wp-rocket.me/de/; Privacy policy: https://wp-rocket.me/privacy-policy/. Further information: Operated within our own hosting environment.

Use of cookies

The term “cookies” refers to functions that store information on users’ devices and read it from them. Cookies can also be used for various purposes, such as ensuring functionality, security and convenience of online offerings, and creating analyses of visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential in order to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information about its scope and which cookies are used.

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

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

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g. browser or mobile application).
  • Persistent cookies: Persistent 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. Likewise, user data collected using cookies can be used for reach measurement. If we do not provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are persistent and that the storage period can be up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to processing in accordance with legal requirements, including via their browser’s privacy settings.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Consent (Art. 6(1) sentence 1 lit. a GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Processing of cookie data on the basis of consent: We use a consent management solution to obtain users’ consent for the use of cookies or for the procedures and providers named within the consent management solution. This procedure serves to obtain, record, manage and withdraw consent, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option to manage and withdraw their consent. The consent declarations are stored in order to avoid having to ask again and to be able to provide proof of consent in accordance with legal requirements. Storage takes place 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. If there is no specific information on the providers of consent management services, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) as well as information about the browser, the system and the device used; Legal basis: Consent (Art. 6(1) sentence 1 lit. a GDPR).
  • BorlabsCookie: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of information on data protection and cookies, enabling users to withdraw or adjust consents; Service provider: Operated on servers and/or computers under our own responsibility under data protection law; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, types of consent and the time they were given are stored server-side and in the cookie on the users’ device.

Contact and enquiry management

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

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and the information relating to them, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, time data, 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 form). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Contact form: If you contact us via our contact form, by email or via other communication channels, we process the personal data you provide to respond to and handle your request. This generally includes information such as name, contact details and, if applicable, other information you share with us that is required for appropriate processing. We use this data exclusively for the stated purpose of contacting and communicating; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Communication via messenger

We use messenger services for communication purposes and therefore ask you to note the following information on the functionality of the messenger services, encryption, the use of communication metadata and your options to object.

You can also contact us via alternative channels, e.g. by phone or email. Please use the contact options provided to you or the contact options listed within our online offering.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger services with encryption enabled to ensure that the encryption of message content is guaranteed.

However, we also point out to our communication partners that although the providers of the messenger services cannot view the content, they may be able to find out that and when communication partners communicate with us, and that technical information about the device used by the communication partners and, depending on their device settings, location information (so-called metadata) is processed.

Information on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you, for example, contact us on your own initiative, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure, and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and fulfilling the needs of our communication partners for communication via messenger. Furthermore, we would like to point out that we do not transmit the contact details provided to us to the messenger for the first time without your consent.

Withdrawal, objection, and deletion: You can withdraw your consent at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policies (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information requested by the communication partners, if no reference to a previous conversation is to be expected and there are no legal retention obligations preventing deletion.

Reservation of referral to other communication channels: To ensure your security, we ask for your understanding that we may not be able to answer inquiries via messenger for certain reasons. This applies to situations in which, for example, contract details must be treated with particular confidentiality or a response via messenger does not meet formal requirements. In these cases, we recommend using more suitable communication channels.

  • Processed data types: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation); usage data (e.g., page views and duration of stay, 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.
  • Purposes of processing and legitimate interests: Communication.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6 (1) (a) GDPR); Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • WhatsApp: A communication service that enables the sending and receiving of text messages, voice messages, images, videos, documents, as well as voice and video calls over the internet. Communication takes place via end-to-end encryption, meaning content is only accessible to the communication partners involved. To provide the service, the platform processes metadata (e.g., phone numbers, timestamps, device information) and can use this to improve functionality, security, and service optimization; Service provider: WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.whatsapp.com/. Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea.

Artificial Intelligence (AI)

We use Artificial Intelligence (AI), whereby personal data is processed. The specific purposes and our interest in using AI are mentioned below. By AI, we mean, in accordance with the term “AI system” pursuant to Article 3 No. 1 of the AI Act, a machine-based system designed to operate with varying levels of autonomy, which may exhibit adaptivity after deployment and which, for explicit or implicit objectives, infers from the input it receives how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for Artificial Intelligence and data protection requirements. In doing so, we particularly adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimization, and integrity as well as confidentiality. We ensure that the processing of personal data is always based on a legal ground. This can be either the consent of the data subjects or a legal permission.

When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with the applicable regulations. Likewise, we observe the obligations incumbent upon us when using or operating the AI services obtained. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We place particular value on transparency, fairness, and maintaining human control over AI-supported decision-making processes.

To protect the processed data, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the processed data and minimize potential risks. Through regular reviews of the AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

  • Processed data types: Content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation). Usage data (e.g., page views and duration of stay, 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). Third parties.
  • Purposes of processing and legitimate interests: Artificial Intelligence (AI).
  • Retention and deletion: Deletion according to 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 Processes, Procedures, and Services:

Video conferencing, online meetings, webinars, and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: As part of participating in a conference, the conference platforms process the personal data of participants mentioned below. The scope of processing depends, on the one hand, on which data is required in the context of a specific conference (e.g., providing access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, the participants’ data can also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (email address, phone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content-related communication processes, i.e., entries in chats as well as audio and video data, as well as the use of other available functions (e.g., surveys). Communication content is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, further data can be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g., from surveys), and video or audio recordings are logged, this will be communicated transparently to the participants in advance and they will be asked for consent – where necessary.

Data protection measures for participants: Please refer to the privacy notices of the conference platforms for details on the processing of your data and choose the security and data protection settings that are optimal for you within the settings of the conference platforms. Furthermore, for the duration of a video conference, please ensure data and privacy protection in the background of your recording (e.g., by informing housemates, locking doors, and using, where technically possible, the background blur function). Links to the conference rooms and access data must not be passed on to unauthorized third parties.

Information on legal bases: If we also process the users’ data in addition to the conference platforms and ask the users for their consent to the use of the conference platforms or certain functions (e.g., consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g., in participant lists, in the case of processing meeting results, etc.). Otherwise, the users’ data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation); usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g., photographs or video recordings of a person); sound recordings; log data (e.g., log files concerning logins or the retrieval of data or access times); contract data (e.g., subject matter of the contract, term, customer category). 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); persons depicted; service recipients and clients; interested parties. Participants.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures. Provision of our online offer and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

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. If the contents of the newsletter are specified in the context of a registration, these contents are decisive for the users’ consent. To register for our newsletter, providing your email address is normally sufficient. However, in order to offer you a personalized service, we may ask you to provide your name for a 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 can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete 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 defense 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 in a blocklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper execution. If 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.

  • Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g., via email or post).
  • Legal bases: Consent (Art. 6 (1) (a) GDPR).
  • Opt-out option: You can cancel the receipt of our newsletter at any time, i.e., withdraw 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 can use one of the contact options given above, preferably email, for this purpose.

Promotional communication via email, post, fax, or telephone

We process personal data for the purposes of promotional communication, which can take place via various channels, such as email, telephone, post, or fax, in accordance with legal requirements.

Recipients have the right to withdraw given consent at any time or to object to promotional communication at any time free of charge via the contact options mentioned above.

After withdrawal or objection, we store the data required to prove the previous authorization for contact or sending for up to three years after the end of the year of withdrawal or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the users’ withdrawal or objection, we also store the data required to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, name).

  • Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Direct marketing (e.g., via email or post); marketing. Sales promotion.
  • Retention and deletion: Deletion according to 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).

Sweepstakes and competitions

We process personal data of participants in sweepstakes and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, execution, and handling of the sweepstakes, the participants have consented to the processing, or the processing serves our legitimate interests (e.g., in the security of the sweepstakes or the protection of our interests against misuse by possible recording of IP addresses when submitting sweepstakes entries).

If participants’ entries are published as part of the sweepstakes (e.g., as part of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we point out that the participants’ names may also be published in this context. Participants can object to this at any time.

If the sweepstakes takes place within an online platform or a social network (e.g., Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection regulations of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by the participants as part of the sweepstakes and that inquiries regarding the sweepstakes should be directed to us.

Participants’ data will be deleted as soon as the sweepstakes or competition has ended and the data is no longer required to inform the winners or because no further queries regarding the sweepstakes are to be expected. In principle, participants’ data will be deleted no later than 6 months after the end of the sweepstakes. Winners’ data can be retained longer, e.g., to answer queries about the prizes or to fulfill the prize services; in this case, the retention period depends on the type of prize and is, for example, up to three years for items or services, e.g., to handle warranty cases. Furthermore, participants’ data can be stored longer, e.g., in the form of reporting on the sweepstakes in online and offline media.

If data was also collected for other purposes as part of the sweepstakes, its processing and retention period are based on the privacy notice for this use (e.g., in the case of registering for the newsletter as part of a sweepstakes).

  • Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation).
  • Data subjects: Sweepstakes and competition participants.
  • Purposes of processing and legitimate interests: Conducting sweepstakes and competitions.
  • Retention and deletion: Deletion according to the information in the section “General information on data storage and deletion”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Surveys and polls

We conduct surveys and polls to collect information for the respective communicated survey or poll purpose. The surveys and polls conducted by us (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed to the extent necessary for the provision and technical execution of the surveys (e.g., processing the IP address to display the survey in the user’s browser or using a cookie to enable the survey to be resumed).

  • Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., text or image messages and posts as well as information concerning them, such as authorship details or time of creation). Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data subjects: Participants.
  • Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form). Surveys and questionnaires (e.g., surveys with input options, multiple-choice questions).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Web analysis, monitoring, and optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offer and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are used most frequently, or invite users to reuse them. It also allows us to understand which areas need optimization.

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

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, can be created for these purposes, and information can be stored in a browser or on an end device and then read out. The collected data includes, in particular, visited websites and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed 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., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) is stored as part of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that both we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

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

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles); Provision of our online offering and user-friendliness. Tracking (e.g., interest-/behavior-based profiling, use of cookies).
  • Retention and deletion: Deletion according to 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 can be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offer 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 serves to assign analysis information to an end device in order to recognize which content users have accessed within one or different usage processes, which search terms they have used, whether they have accessed it again, or have interacted with our online offer. Likewise, the time of use and its duration are stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
    In the process, pseudonymous profiles of users are created with information from the use of different devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse 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 counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible, and is not used for further purposes. When Google Analytics collects measurement data, all IP lookups are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 (1) (a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).
  • Google Tag Manager: We use Google Tag Manager, a software from Google that allows us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that serve to record and analyze visitor activities. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles, and does not perform independent analyses. Its function is limited to simplifying and making the integration and management of tools and services that we use on our website more efficient. Nevertheless, when using Google Tag Manager, the users’ IP address is transmitted to Google, which is technically necessary to implement the services we use. Cookies can also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, we refer to the further sections of this privacy policy; 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; Privacy Policy: https://business.safety.google/privacy/; Data Processing Agreement:
    https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms).
  • Cloudflare Web Analytics: Web analysis, reach measurement, and analysis of user behavior regarding usage and interests concerning functions and content, as well as their duration of use, based on a pseudonymous user identification number and profile creation; Service Provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.cloudflare.com/web-analytics/; Privacy Policy: https://www.cloudflare.com/privacypolicy/; Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.cloudflare.com/cloudflare-customer-scc/).

Presences on social networks (Social Media)

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

We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because 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 can be created based on user behavior and resulting interests. The latter may in turn be used to display advertisements within and outside the networks that presumably correspond to the users’ interests. Therefore, cookies are generally stored on users’ computers, in which the users’ usage behavior and interests are stored. In addition, data can also be stored in the usage profiles independently of the devices used by the users (especially if they are members of the respective platforms and logged in there).

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

Also, in the case of information requests and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts, and information related to them, such as authorship details 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 form). Public relations.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Instagram: Social network, enables sharing photos and videos, commenting and liking posts, sending messages, subscribing to profiles and pages; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – 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 (“Fanpage”). This includes, in particular, information about user behavior (e.g., viewed or interacted content, actions performed) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). More details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the “Page Insights” service, which provide insights into how people interact with our page and its content. The basis for this is an agreement with Facebook (“Information on 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 can therefore address requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
  • YouTube: Social network and video platform; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://business.safety.google/privacy/; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF). Option to object (Opt-Out): https://myadcenter.google.com/.

Processing of data in the context of employment relationships

Within the framework of employment relationships, personal data is processed with the aim of effectively establishing, carrying out, and terminating such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.

Data processing encompasses various aspects, ranging from contract initiation to contract termination. This includes the organization and management of daily working hours, the administration of access rights and permissions, and the handling of personnel development measures and employee appraisals. The processing also serves payroll and salary payment administration, which are critical aspects of contract execution.

Additionally, data processing considers the legitimate interests of the responsible employer, such as ensuring workplace safety or collecting performance data for evaluating and optimizing operational processes. Furthermore, data processing includes the disclosure of employee data within the scope of external communication and publication processes, where this is necessary for operational or legal purposes.

The processing of this data always takes place in compliance with the applicable legal frameworks, with the constant goal of creating and maintaining a fair and efficient working environment. This also includes considering the data protection of the affected employees, anonymizing or deleting data after the processing purpose has been fulfilled or according to statutory retention periods.

  • Types of data processed: Employee data (information about employees and other persons in an employment relationship); Payment data (e.g., bank details, invoices, payment history); Contract data (e.g., subject of contract, term, customer category); Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and posts, and information related to them, such as authorship details or time of creation); Social data (data subject to social secrecy and processed, for example, by social insurance providers, social welfare providers, or supply authorities); Log data (e.g., log files concerning logins or data retrieval or access times); Performance and behavior data (e.g., performance and behavioral aspects such as performance reviews, feedback from supervisors, training participation, compliance with company policies, self-assessments and behavioral assessments); Working time data (e.g., start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); Salary data (e.g., basic salary, bonuses, premiums, tax class information, surcharges for night work/overtime, tax deductions, social security contributions, net payout amount); Image and/or video recordings (e.g., photographs or video recordings of a person); 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, involved persons).
  • Special categories of personal data: Health data; Religious or philosophical beliefs. Trade union membership.
  • Data subjects: Employees (e.g., salaried employees, applicants, temporary staff, and other employees). Business and contract partners.
  • Purposes of processing and legitimate interests: Establishment and execution of employment relationships (processing of employee data within the framework of establishing and executing employment relationships); Business processes and commercial procedures; Security measures; Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures. Public relations.
  • Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 para. 2 lit. h) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Time Recording: Procedures for recording employee working hours include both manual and automated methods, such as the use of time clocks, time tracking software, or mobile apps. Activities such as entering arrival and departure times, break times, overtime, and absences are carried out. To verify and validate recorded working hours, reconciliation with deployment or shift plans, verification of absences, and approval of overtime by supervisors are included. Reports and analyses are generated based on recorded working hours to provide working time records, overtime reports, and absence statistics for management and the HR department; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Authorization Management: Procedures required for defining, managing, and controlling access rights and user roles within a system or organization (e.g., creation of authorization profiles, role- and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Special categories of personal data: Special categories of personal data are processed within the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data concerning health, trade union membership, or religious affiliation of employees. This data may, for example, be passed on to health insurance companies or processed for assessing the employee’s ability to work, for occupational health management, or for providing information to the tax office; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Sources of processed data: Personal data obtained during the application and/or employment relationship of employees is processed. In addition, if legally required, personal data is collected from other sources. These may include financial authorities for tax-relevant information, the respective health insurance company for information on incapacity to work, third parties such as employment agencies, or publicly accessible sources such as professional social networks in the context of application procedures; Legal Basis: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Video Surveillance: Employee monitoring serves the security of the company, the protection of property, and the safety of employees. Various procedures and data processing steps are carried out for this.
    First, surveillance cameras are installed and positioned after a site analysis to identify security-relevant areas. Subsequently, the cameras are installed at suitable locations, with indications of surveillance potentially provided by signs or warnings.
    Regular checks are carried out to ensure that the cameras are functioning correctly and that there are no failures that could compromise security.
    The actual surveillance involves conducting video recordings to capture and document potential security incidents. These recordings are then evaluated and analyzed to identify suspicious activities and respond appropriately.
    All recorded video data is archived in accordance with legal regulations and data protection guidelines. It should be noted that the data will be deleted after a maximum of 96 hours, unless there is a concrete suspicion that requires longer retention to clarify the facts or ensure the security of the company.
    In addition, measures for data deletion are implemented as soon as the retention periods have expired or the data is no longer needed, in order to comply with data protection guidelines and protect the privacy of employees; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Purposes of data processing: The personal data of employees is primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to meet regulatory and supervisory requirements, to optimize electronic data processing processes, and to compile company-internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for asserting legal claims and defending against legal disputes; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transmission of employee data: Employee data is processed internally only by those departments that require it to fulfill operational, contractual, and legal obligations.
    Data is only passed on to external recipients if this is legally required or if the affected employees have given their consent. Possible scenarios for this may be requests for information from authorities or in the case of capital-forming benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance companies, pension insurance providers, old-age provision providers, and other social security providers c) Authorities, courts (e.g., tax authorities, labor courts, other supervisory authorities in the context of fulfilling reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the case of wage and salary garnishments f) Other bodies to which legally binding declarations must be made.
    In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender area of emails or letterheads, as well as the creation of profiles on external platforms; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Transfer of employee data to third countries: The transfer of employee data to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the fulfillment of the employment relationship, is legally required, or if employees have given their consent. Employees will be informed separately about the details, as far as legally required; Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Business Trips and Travel Expense Accounting: Procedures required for the planning, execution, and accounting of business trips (e.g., booking trips, organizing accommodation and transportation, managing travel expense advances, submitting and reviewing travel expense reports, controlling and posting incurred costs, complying with travel policies, handling travel expense management); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Payroll and Wage Accounting: Procedures required for the calculation, payment, and documentation of wages, salaries, and other remuneration for employees (e.g., recording working hours, calculating deductions and surcharges, remitting taxes and social security contributions, preparing wage and salary statements, maintaining wage accounts, reporting to the tax office and social security institutions); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
  • Deletion of employee data: Employee data is deleted under German law if it is not required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the employer’s interests. The following retention and archiving obligations are observed:
    • General personnel records – General personnel records (such as employment contracts, references, supplementary agreements) are retained for up to three years after the termination of the employment relationship (§ 195 BGB).
      Tax-relevant documents – Tax-relevant documents in the personnel file are retained for six years (§ 147 AO, § 257 HGB).
      Information on wages and working hours – Information on wages and working hours for (accident) insured persons with wage statements is retained for five years (§ 165 I 1, IV 2 SGB VII).
    • Salary lists including lists for special payments – Salary lists including lists for special payments, if a booking voucher is available, are retained for ten years (§ 147 AO, § 257 HGB).
    • Wage lists for interim, final, and special payments – Wage lists for interim, final, and special payments are retained for six years (§ 147 AO, § 257 HGB).
    • Documents for employee insurance – Documents for employee insurance, if booking vouchers are available, are retained for ten years (§ 147 AO, § 257 HGB).
    • Contribution statements to social security institutions – Contribution statements to social security institutions are retained for ten years (§ 165 SGB VII).
      Wage accounts – Wage accounts are retained for six years (§ 41 I 9 EStG).
    • Applicant data – Retained for a maximum of six months from receipt of rejection.
    • Working time records (for more than 8 hours on weekdays) – Retained for two years (§ 16 II Working Hours Act (ArbZG)).
    • Application documents (after online job advertisement) – Retained for three to a maximum of six months after receipt of rejection (§ 26
    • Federal Data Protection Act (BDSG) n.F., § 15 IV General Equal Treatment Act (AGG)).
    • Certificates of incapacity for work (AU) – Retained for up to five years (§ 6 I Compensation for Expenses Act (AAG)).
    • Documents on company pension schemes – Retained for 30 years (§ 18a Act to Improve Company Pension Schemes (BetrAVG)).
    • Health data of employees – Retained for twelve months after the start of the illness if absences do not exceed six weeks in one year.
    • Documents on maternity protection – Retained for two years (§ 27 para. 5 MuSchG).

    Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 para. 2 lit. h) GDPR).

  • Deletion of employee data: Employee data is deleted under Austrian law if it is not required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the employer’s interests. The following retention and archiving obligations are observed:
    • Data concerning income tax and levy obligations according to § 132 para. 1 BAO – 7 years. Start of period – From the end of the respective calendar year relevant for the data.
    • Statute of limitations for the obligation to pay social security contributions according to § 68 ASVG (determination limitation) – 3 or 5 years. Start of period – Generally from the due date of the contributions, in case of omitted notification from the date of notification.
    • Retention periods in social security – 7 years according to UGB.
    • Right to vacation according to § 4 para. 5 UrlG – 2 years from the end of the vacation year in which the vacation accrued. Start of period – 2 years after the end of the vacation year in which the vacation accrued.
    • Claim for vacation compensation according to § 1486 Z 5 ABGB – 3 years. Start of period – From the due date of the final settlement claims, i.e., the last working day.
    • Records and reports on occupational accidents according to § 16 ASchG – at least 5 years. Start of period – From the day of the occupational accident.
    • Record of temporary agency work according to § 13 para. 3 AÜG – 5 years. Start of period – The day on which the last wage claim of the temporary worker becomes due.
    • Youth register according to § 26 para. 2 KJBG – 2 years. Start of period – for new creation of the register, two years after the last entry.
    • Claims for compensation due to discriminatory termination of employment according to §§ 15 para. 1a and 29 para. 1a GlBG as well as § 7k para. 1 in conjunction with para. 2 Z 3 BEinstG – 6 months. Start of period – From the time of receipt of the termination.
    • Employer’s or employee’s claims for compensation arising from premature termination of employment according to § 34 AngG or § 1162d ABGB – 6 months. Start of period – From the due date of the claims, usually from the date of receipt of the declaration of termination.
    • Claim for issuance of an employment reference according to § 1478 ABGB – 30 years. Start of period – Upon termination of the employment relationship.
    • Claims for compensation due to discriminatory rejection of an application according to §§ 15 para. 1 and 29 para. 1 GlbG as well as § 7k para. 1 in conjunction with para. 2 Z 1 BEinstG – 6 months. Start of period – from the day the rejection was received or 7 months from receipt of application.
    • Claims for reimbursement of any presentation costs according to § 1486 Z 5 ABGB – 3 years. Start of period – The day the costs were incurred.
    • Liability for severance pay claims and company pensions after business transfer according to § 6 para. 2 AVRAG – 5 years. Start of period – Time of business transfer.
    • Claims for compensation due to discriminatory rejection of a promotion according to §§ 15 para. 1 and 29 para. 1 GlbG as well as § 7k para. 1 in conjunction with para. 2 Z 1 BEinstG – 6 months. Start of period – from the day the rejection of the promotion was received.
    • Claims for compensation due to discriminatory disadvantage in remuneration, voluntary social benefits, training and further education measures, or other working conditions according to §§ 15 para. 1 and 29 para. 1 GlbG as well as § 7k para. 1 in conjunction with para. 2 Z 5 BEinstG – 3 years. Start of period – The time when the right could first have been exercised and there was an objective possibility to sue.
    • Claims for compensation due to discriminatory harassment according to §§ 15 para. 1 and 29 para. 1 GlbG as well as § 7k para. 1 in conjunction with para. 2 Z 4 BEinstG – 1 year. Start of period – From the time of knowledge of the discrimination.
    • Claims for compensation due to discriminatory rejection of an application according to §§ 15 para. 1 and 29 para. 1 GlbG as well as § 7k para. 1 in conjunction with para. 2 Z 1 BEinstG – 6 months. Start of period – from the day the rejection was received or 7 months from receipt of application.
    • Claims for compensation due to sexual harassment according to § 15 para. 1 GlbG – 3 years. Start of period – From the time of knowledge of the discrimination.
    • Claims for reimbursement of any presentation costs according to § 1486 Z 5 ABGB – 3 years. Start of period – The day the costs were incurred.
    • Employee’s claims for remuneration or reimbursement of expenses, as well as employer’s claims for advances granted thereon, according to § 1486 Z 5 ABGB – 3 years. Start of period – from the due date of the respective claims.
    • Statute of limitations for prosecution due to underpayment according to § 31 para. 1 VStG in conjunction with § 29 para. 4 LSD-BG – 3 years. Start of period – from the due date of the remuneration.
    • Employer’s claims for damages against the employee from employee liability for slight negligence according to § 6 DHG – 6 months. Start of period – from the day they can be asserted.
    • Employer’s claims for damages against the employee from employee liability for gross negligence or intent, as well as other employer’s claims for damages according to § 1489 ABGB – 3 years or 30 years. Start of period – For short period from knowledge of damage and perpetrator, for long period from occurrence of damage.
  • Personnel File Management: Procedures required for the organization, updating, and administration of employee data and documents (e.g., recording master data, retaining employment contracts, references, and certificates, updating data in case of changes, compiling documents for employee appraisals, archiving personnel files, complying with data protection regulations); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 para. 2 lit. h) GDPR).
  • Personnel Development, Performance Appraisal, and Employee Appraisals: Procedures required in the area of promoting and developing employees, as well as in assessing their performance and in the context of employee appraisals (e.g., needs analysis for further training, planning and implementation of training measures, creation of performance appraisals, conducting target agreement and feedback discussions, career planning and talent management, succession planning); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to healthcare, occupation, and social security (Art. 9 para. 2 lit. h) GDPR).
  • Obligation to provide data: The controller informs employees that the provision of their data is necessary. This is generally the case if the data is required for the establishment and execution of the employment relationship or its collection is legally prescribed. The provision of data may also be necessary if employees assert claims or claims are due to employees. The implementation of these measures or fulfillment of services depends on the provision of this data (for example, the provision of data for the purpose of receiving wages); Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if this is necessary for the performance of work duties according to the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website, or in public registers after consultation or agreed job description, or if the scope of duties includes representative functions. This may also be the case if, in the course of performing duties, a presentation or communication with the public takes place, such as image recordings in the context of public relations. Otherwise, employee data will only be published with their consent or on the basis of the employer’s legitimate interests, for example, for stage or group photos at a public event; Legal Basis: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. What information is required can be found in the job description or, in the case of online forms, in the information provided there.

Generally, the required information includes personal details such as name, address, contact information, and proof of qualifications necessary for a position. Upon request, we will gladly provide additional information on what details are needed.

If available, applicants are welcome to submit their applications via our online form, which is encrypted using the latest technology. Alternatively, it is also possible to send applications to us by email. However, we would like to point out that emails are generally not sent encrypted over the internet. Although emails are usually encrypted during transmission, this does not apply to the servers from which they are sent and received. Therefore, we cannot assume responsibility for the security of the application during its transmission path between the sender and our server.

For the purposes of applicant search, submission of applications, and selection of applicants, we may use applicant management or recruitment software and platforms and services from third-party providers, in compliance with legal requirements.

Applicants are welcome to contact us regarding the method of submitting their application or to send us the application by post.

Processing of special categories of data: If special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severe disability status or ethnic origin) are requested from applicants or communicated by them during the application process, their processing takes place so that the controller or the data subject can exercise the rights arising from employment law and the law of social security and social protection and fulfill their respective obligations, in the case of protecting vital interests of applicants or other persons, or for purposes of health care or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector, or for the administration of systems and services in the health or social sector.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the case of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion takes place, subject to a legitimate withdrawal by the applicants, no later than after a period of six months, so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process, and they can withdraw their consent at any time for the future.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as details about authorship or time of creation). Applicant data (e.g. personal information, postal and contact addresses, documents belonging to the application and the information contained therein, such as cover letter, CV, certificates, as well as other information voluntarily provided by applicants regarding their person or qualifications with regard to a specific position).
  • Data subjects: Applicants.
  • Purposes of processing and legitimate interests: Application process (establishment and possible subsequent performance as well as possible subsequent termination of the employment relationship).
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Privacy Information for Whistleblowers

In this section you will find information about how we handle data from persons who provide information (whistleblowers), as well as from affected and involved parties within the framework of our whistleblower procedure. Our goal is to provide a straightforward and secure way to report possible misconduct by us, our employees, or service providers, particularly for actions that violate laws or ethical guidelines. We also ensure appropriate processing and handling of the reports.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); Employee data (information about employees and other persons in an employment relationship); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or pictorial messages and posts as well as information concerning them, such as details about 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 features).
  • Data subjects: Service recipients and clients; Employees (e.g. staff, applicants, temporary workers, and other employees); Third parties. Whistleblowers.
  • Purposes of processing and legitimate interests: Whistleblower protection.
  • Retention and deletion: Deletion in accordance with information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further Information on Processing Processes, Procedures, and Services:

  • Types of data processed:

    In the context of receiving and processing reports as well as in the subsequent whistleblower procedure, we may collect various data. This includes in particular the data provided by a whistleblower, such as:

      • Name, contact details, and location of the person providing the tip,
      • Names and data of potential witnesses or persons affected by the tip,
      • Names and data of the persons against whom the tip is directed,
      • Data about the alleged misconduct,
      • Further relevant details, if provided by the whistleblower.

    For the purposes of investigating the facts and the further procedure, we also process the following personal data:

      • Clear identification of the report,
      • Contact details of the reporting person, if provided,
      • Personal data of persons mentioned in the report, if provided,
      • Personal data of persons indirectly affected by the factual review, if applicable,
      • Personal data of persons from other involved companies (e.g., in the context of legal advice), if relevant,
      • Further data related to the matter.

    –

    In the context of receiving and processing reports as well as in the subsequent whistleblower procedure, we may collect various data. This includes in particular the data provided by a whistleblower, such as:

    • Name, contact details, and location of the person providing the report,
    • Names and data of possible witnesses or persons affected by the report,
    • Names and data of the persons against whom the report is directed,
    • Data about the alleged misconduct,
    • Further relevant details, if communicated by the whistleblower.

    For the purposes of investigating the facts and the further procedure, we also process the following personal data:

    • Unique identification of the report,
    • Contact details of the reporting person, if provided,
    • Personal data of persons named in the report, if provided,
    • Personal data of persons indirectly affected by the investigation, if applicable,
    • Personal data of persons from other involved companies (e.g. in the context of legal advice), if relevant,
    • Further data related to the facts.
  • Special categories of personal data:

    It may occur that we collect special types of personal data in the course of our activities, particularly when these are communicated by a whistleblower. These include:

    • Health-related data of a person,
    • Data on racial or ethnic origin of persons,
    • Information about religious or philosophical beliefs of a person,
    • Information about sexual orientation of a person.

    This data is only processed if it is relevant to the processing of the respective report and has been expressly provided by the whistleblower.

    .

  • Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in your browser’s so-called ‘incognito mode’. Here’s how to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

    When accessing our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This also includes the IP address of your device. This data is temporarily stored in a log file and automatically deleted after 30 days at the latest.

    The processing of the IP address serves technical and administrative purposes for establishing the connection to our website. It ensures the security, stability, and functionality of the whistleblower form and is an important component of our measures to ensure confidential reporting.

    The processing of the logged data is based on Article 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest lies in the need for security and the necessity to ensure the technical prerequisites for smooth and trouble-free reporting; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

  • Providing your name: You have the option to submit reports anonymously. Unless prohibited by national legislation, we recommend providing your name and contact details. This enables us to follow up on the report more effectively and, if necessary, contact you directly.

    If you provide your name and contact details, your identity will be treated in strict confidence. Exceptions to this confidentiality exist only if we are legally obliged to disclose your identity. This may be necessary to protect or defend our rights or the rights of our employees, customers, suppliers, or business partners. Another exception exists if it is determined that the allegations were made with malicious intent.

  • Disclosure of data to third parties: Data related to the submitted reports will only be disclosed to third parties under certain circumstances. This occurs either a) if you have given us your express consent to do so, or b) if there is a legal obligation to disclose the data. Possible third parties include public authorities, government, regulatory, or tax authorities, if the disclosure is necessary to fulfill a legal or regulatory obligation. In addition, we may engage lawyers and other professional advisors within the framework of legal provisions. They are authorized to examine suspected misconduct and take necessary measures after an investigation, such as initiating disciplinary or legal proceedings. Furthermore, carefully selected and monitored service providers may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations within the framework of data processing.
  • Data retention and deletion: Personal data is only processed for as long as necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations, however, the data may be retained longer to meet legal requirements, as long as this is necessary and proportionate. In such cases, the data will be deleted as soon as it is no longer required for these purposes.
  • Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes. Incoming reports are processed by authorized persons who have access to the respective reports and carry out the subsequent investigation of the facts. Our employees are specially trained and instructed in the proper conduct of investigations and are obliged to maintain the strictest confidentiality.

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your participation (e.g. consent) or other individual notification.

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

Definitions of Terms

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

  • Employees: Employees are persons who are in an employment relationship, whether as workers, staff, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration while the employee provides their work performance. The employment relationship encompasses various phases, including establishment, in which the employment contract is concluded, performance, in which the employee carries out their work activity, and termination, when the employment relationship ends, whether through dismissal, termination agreement, or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance evaluations.
  • Master data: Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, facilities, or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data can 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 but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to recognize patterns, make predictions, and improve the efficiency and quality of our services. This includes the collection, cleaning, and structuring of data, the training and application of AI models, as well as the continuous review and optimization of results, and is carried out exclusively with the consent of users or on the basis of legal authorization.
  • Performance and behavioral data: Performance and behavioral data refers to information related to how persons complete tasks or behave in a particular context, such as in an educational, work, or social environment. This data may include metrics such as productivity, efficiency, work quality, attendance, and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes, and responses to various situations. These types of data are often used for performance evaluations, training and development measures, and decision-making within organizations.
  • Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include information about file size, creation date, author of a document, and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used to track and review operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide 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 can also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing 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, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior, 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 to analyze system problems, for security monitoring, or to create performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate visitor flows to an online offering and can include the behavior or interests of visitors in certain information, such as content of websites. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis purposes to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Tracking: “Tracking” refers to when the behavior of users can be traced across multiple online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of tracking technologies with regard to the online offerings used (so-called profiling). This information can then be used, for example, to show users advertisements that presumably correspond to their interests.
  • Controller: The “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 covers practically any handling of data, whether it is collection, evaluation, storage, transmission, or deletion.
  • Contract data: Contract data is specific information relating to the formalization 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 fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include 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.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is crucial for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information about payment status, chargebacks, authorizations, and fees.