Privacy Policy

Note: This is an English translation provided as a courtesy. The legally binding version under German and EU law is the German Datenschutzerklärung.

Preamble

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

The terms used are not gender-specific.

Last updated: 3 May 2026

Table of contents

• Preamble
• Controller
• Overview of processing activities
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Commercial services
• Provision of the online offering and web hosting
• Use of cookies
• Contact and inquiry management
• Presence on social networks (social media)
• Links to external websites
• Changes and updates
• Definitions

Controller

Alejandro Gutierrez Cornelio
AGC Consult
Friedenstraße 59
97072 Würzburg
Germany

Email: contact@agcconsult.com

Phone: +49 151 53670130

Imprint: https://agcconsult.com/impressum.html

Overview of processing activities

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

Types of data processed

• Master data.
• Employee data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication, and procedural data.
• Log data.

Categories of data subjects

• Service recipients and clients.
• Employees.
• Prospective customers.
• Communication partners.
• Users.
• Business and contractual partners.
• Third parties.
• Whistleblowers.

Purposes of processing

• Provision of contractual services and fulfilment of contractual obligations.
• Communication.
• Security measures.
• Office and organisational procedures.
• Organisational and administrative procedures.
• Feedback.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Whistleblower protection.
• Public relations.
• Business processes and economic procedures.

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 GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in individual cases, more specific legal bases apply, we will inform you of these in the privacy policy.

• Consent (Art. 6 (1) sentence 1 lit. a GDPR) – The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
• Performance of a contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR) – The processing is necessary for the performance of a contract to which the data subject is party, or for the implementation of pre-contractual measures taken at the data subject's request.
• Legal obligation (Art. 6 (1) sentence 1 lit. c GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR) – Processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject which require the protection of personal data do not override.

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

Security measures

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

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 it, input, transmission, ensuring availability, and its segregation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account during the development and selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

Securing online connections via TLS/SSL encryption (HTTPS): To protect the user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the 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 signalled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transmission of personal data

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

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 using third-party services or the disclosure or transfer of data to other persons, entities, or companies (which is recognisable from the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with statutory requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

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

In the case of individual service providers, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. You can find further information on the DPF and a list of certified companies on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission's website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General information on data storage and deletion

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

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

Where there are several specifications regarding the retention period or deletion deadlines for a given piece of data, the longest period shall apply. Data that is no longer retained for the originally intended purpose, but rather due to legal requirements or other reasons, is processed exclusively for the reasons that justify its retention.

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

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as work instructions and other organisational documents necessary for their understanding (§ 147 (1) no. 1 in conjunction with (3) AO, § 14b (1) UStG, § 257 (1) no. 1 in conjunction with (4) HGB).
• 8 years – Accounting documents such as invoices and cost receipts (§ 147 (1) no. 4 and 4a in conjunction with (3) sentence 1 AO and § 257 (1) no. 4 in conjunction with (4) HGB).
• 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operational accounting sheets, calculation documents, price labels, but also wage accounting documents insofar as they are not already accounting documents and cash register strips (§ 147 (1) no. 2, 3, 5 in conjunction with (3) AO, § 257 (1) no. 2 and 3 in conjunction with (4) HGB).
• 3 years – Data necessary to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

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

Rights of data subjects

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

• Right to object: You have the right, on grounds arising from your particular situation, to object at any time to processing of personal data concerning you which is based on Article 6 (1) lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for 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 the data in question is being processed and to obtain information about this data, as well as further information and copies of the data in accordance with statutory requirements.
• Right to rectification: You have the right, in accordance with statutory requirements, to request the completion of data concerning you or the rectification of incorrect data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with statutory requirements, to demand that data concerning you be deleted without delay, or alternatively, to demand a restriction of processing of the data in accordance with statutory requirements.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with statutory requirements, or to demand its transmission to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Commercial services

We process the personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken on request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfil our principal and ancillary contractual obligations. This includes the provision of the agreed services, any update and information obligations, the handling of warranty and other performance disturbances, the processing of cancellations, terminations of long-term obligations, reversals, refunds, and the handling of other contract-related declarations and inquiries. Both one-off contracts and ongoing contractual relationships are covered.

In particular, we process master data such as name, address, and any company name, contact data such as email address and telephone number, contract and service data such as the subject of the contract, contract duration, order or transaction number, usage and service data, payment and billing data, as well as communication content and history. Where necessary, we also process data disclosed or transmitted to us in the context of the execution of an order.

In addition, we process the data to safeguard our rights and to fulfil legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations, and any obligations to provide evidence and accountability. Furthermore, processing takes place on the basis of our legitimate interests in proper business management, internal administration, risk management, and IT security, as well as the protection of our business operations and our contractual partners against 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 vicarious agents, insofar as this is necessary for the execution of the contract or the fulfilment of legal obligations.

Personal data is only passed on to third parties to the extent necessary for the performance of the contract, the implementation of pre-contractual measures, the protection of legitimate interests, or the fulfilment of legal obligations. Any further processing, in particular for marketing purposes, is communicated separately within the framework of this privacy policy.

We will inform contractual partners of which data is required in individual cases as part of data collection, e.g. in online forms by appropriate marking or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations stand in the way. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in connection with a specific order is deleted by us after completion of the order and expiration of any retention periods, provided there are no further legal or contractual obligations to store it.

The legal basis for processing is Art. 6 (1) lit. b GDPR for the implementation of pre-contractual measures and the fulfilment of the respective contractual relationship, and Art. 6 (1) lit. c GDPR for the fulfilment of legal obligations. Where the processing is based on legitimate interests, it takes place on the basis of Art. 6 (1) lit. f GDPR. Where processing is based on Art. 6 (1) lit. f GDPR, it serves the protection of our legitimate interests in proper and efficient business organisation, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations.

• Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject of 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; communication; office and organisational procedures; organisational and administrative procedures; business processes and economic procedures.
• Retention and deletion: Deletion in accordance with 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) sentence 1 lit. b GDPR); legal obligation (Art. 6 (1) sentence 1 lit. c GDPR); legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further information on processing operations, procedures, and services:

• Agency services: We process the data of our customers in the context of our contractual services, which may include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).
• Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") to enable them to select, acquire, or commission the chosen services or works and related activities, as well as to pay for and provide or perform them.
  
  The required information is identified as such in the context of the order, purchase, or comparable contract conclusion and includes the information needed for the provision of services and billing, as well as contact information to be able to make any necessary inquiries. Insofar as we obtain access to information of end customers, employees, or other persons, we process this in accordance with statutory and contractual requirements; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).

Provision of the online offering and web hosting

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

• Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times); content data (e.g. text or image messages and posts as well as related information such as authorship or time of creation).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
• Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further information on processing operations, procedures, and services:

• Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software which we rent or otherwise obtain from a corresponding server provider (also called a "web host"); Legal bases: 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". Server log files may include the address and name of the websites and files accessed, date and time of access, transmitted data volumes, message of successful access, browser type along with 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 case of malicious attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident is finally clarified.
• Email sending and hosting: The web hosting services we use also include the sending, receipt, and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information regarding email transmission (e.g. the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. We ask you to note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted during transport, but (unless an end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of emails between the sender and reception on our server; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).
• Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that helps deliver the contents of an online offering, especially large media files such as graphics or program scripts, faster and more securely with the help of regionally distributed servers connected via the internet; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Hosting and infrastructure provider in use: Cloudflare

For hosting and provision of our online offering, we use the services of Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA (hereinafter "Cloudflare"). Cloudflare is used by us for several interconnected functions:

• Cloudflare Pages – hosting of static website content and global delivery via the Cloudflare Content Delivery Network (CDN).
• Cloudflare Workers – server-side processing of contact form submissions (validation, spam protection, handover to the email sending service).
• Cloudflare Email Routing – forwarding of emails sent to contact@agcconsult.com to our personal mailbox.

Each time our online offering is accessed, technically necessary data is processed via the Cloudflare infrastructure, in particular the IP address, the user-agent (browser type and version), the referrer (previously visited page), the date and time of access, and the transmitted data volume.

Third-country transfer: Data processing takes place in part on servers in the USA. Cloudflare is certified under the EU-US Data Privacy Framework (DPF). In addition, we have concluded a data processing agreement (standard contractual clauses) with Cloudflare.

Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in stable, secure, and performant provision of the online offering).

Provider's privacy policy: https://www.cloudflare.com/privacypolicy/

Data Processing Agreement (DPA): https://www.cloudflare.com/cloudflare-customer-dpa/

Use of cookies

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies can also be used in connection with various concerns, e.g. for purposes of functionality, security, and convenience of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with statutory provisions. Where required, we obtain users' prior consent. If consent is not necessary, we rely on our legitimate interests. This applies if storing and reading information is essential to be able to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of consent and which cookies are used.

Notes on data protection legal bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as a 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 has left an online offering and closed their device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the device has been closed. For example, the login status can be stored and preferred content displayed directly when the user revisits a website. Likewise, user data collected via cookies can be used for reach measurement. Insofar as we do not provide users with explicit information on the type and storage period of cookies (e.g. as part of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General notes on revocation and objection (opt-out): Users can revoke consents they have given at any time and also object to processing in accordance with statutory requirements, including via their browser's privacy settings.

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

Cookies actually used

This website uses exclusively one technically necessary cookie:

Consent is not required for this under § 25 (2) no. 2 TTDSG (German Telecommunications-Telemedia Data Protection Act), as the cookie is strictly necessary for the provision of a service expressly requested by the user (language switching). No tracking, analytics, or advertising cookies are set. You can delete the cookie at any time via your browser's privacy settings.

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone, or via social media) and within existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries 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 as well as related information such as authorship or time of creation); meta, communication, and procedural data (e.g. IP addresses, time stamps, 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 the information in the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); performance of a contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR).

Further information on processing operations, procedures, and services:

• Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data transmitted to us to answer and process the respective inquiry. This usually includes information such as name, contact information, and any other information communicated to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b GDPR), legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Specific processing via our contact form

Via the contact form on agcconsult.com, we process the following information:

• Required fields: Name, email address, company, message (minimum 10 characters).
• Optional field: Preferred date for a discovery call.

The form additionally contains a hidden field ("honeypot") for the automatic detection and prevention of spam bots. No external CAPTCHA system is used.

Data flow: After submission, the entries are first transmitted in encrypted form (HTTPS) to a Cloudflare Worker. This validates the data, checks the honeypot field, and then hands over email sending to the service provider Resend (Resend, Inc., 2261 Market Street #4242, San Francisco, CA 94114, USA). The recipient address contact@agcconsult.com is forwarded via Cloudflare Email Routing to our personal mailbox.

Third-country transfer: Processing via Cloudflare and Resend takes place in part in the USA. Both providers are certified under the EU-US Data Privacy Framework; in addition, standard contractual clauses are in place.

Storage period: We store the transmitted data for as long as is necessary to process your inquiry. If a contractual relationship subsequently arises, the commercial and tax law retention periods apply (see section "General information on data storage and deletion").

Legal bases: Art. 6 (1) lit. b GDPR (initiation of a contractual relationship) and Art. 6 (1) lit. f GDPR (legitimate interest in efficient processing of inquiries).

Email sending service provider in use – Resend: Resend is used exclusively for the technical sending of emails received via the contact form to our own mailbox. A data processing agreement (DPA) has been concluded with Resend.

Resend privacy policy: https://resend.com/legal/privacy-policy

Resend Data Processing Agreement: https://resend.com/legal/dpa

Presence on social networks (social media)

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

We point out that user data may be processed outside the European Union. This may give rise to risks for users, as it could, for example, make it more difficult to enforce user rights.

Furthermore, the data of users within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the user behaviour and the resulting interests of the users. The latter may in turn be used to display advertisements within and outside the networks that presumably correspond to the interests of the users. For this purpose, cookies are usually stored on the users' computers, in which the usage behaviour and interests of the users are stored. In addition, data can be stored in the usage profiles regardless of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

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

Even in the case of inquiries about information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can take corresponding measures and provide information directly. If you nevertheless 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. text or image messages and posts as well as related information such as authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via online form); public relations.
• Retention and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR).

Further information on processing operations, procedures, and services:

• Instagram: Social network, enables sharing of photos and videos, commenting and favouriting posts, message sending, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
• LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors used to create the "Page Insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Information about the devices used is also collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information about the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.
  
  We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information requests or deletion requests directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular regarding the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 (1) sentence 1 lit. f GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Links to external websites

Our privacy policy and our imprint contain references to third-party websites, such as supervisory authorities, EU platforms, the privacy policies of our service providers, and the sources of our legal texts (license attributions). When you click on such a link, you are redirected to the respective external website, whereby your IP address and browser information are transmitted to the provider of that website.

We have no influence on the data processing taking place there. The respective privacy policies of the external providers apply. Automatic transmission of your data to these entities does not take place when our website is merely accessed.

Changes and updates

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

If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please verify the information before contacting us.

Competent supervisory authority

Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18
91522 Ansbach
Germany

Phone: +49 981 180093-0
Email: poststelle@lda.bayern.de
Internet: https://www.lda.bayern.de

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their statutory definitions apply. The following explanations, on the other hand, are intended primarily to aid understanding.

• Employees: Employees are persons in an employment relationship, whether as workers, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established through an employment contract or agreement. It involves the employer's obligation to pay the employee remuneration while the employee provides their work performance. The employment relationship comprises various phases, including its establishment (in which the employment contract is concluded), its execution (in which the employee performs their work activity), and its termination (when the employment relationship ends, whether by termination, dismissal agreement, or otherwise). Employee data is all information relating to these persons that is connected with their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, leave entitlements, health data, and performance assessments.
• Master data: Master data comprises 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, institutions, 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 may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content 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 organisations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about the way 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, the author of a document, and change history. Communication data captures the exchange of information between users via various channels, such as email traffic, call protocols, messages on social networks, and chat histories, including the persons involved, time stamps, and transmission paths. Procedural data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to track and verify operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they spend on certain pages, and which paths they navigate through an application. Usage data may also include the frequency of use, time stamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences, and possible 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.
• 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 time stamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used for analysing system problems, security monitoring, or creating performance reports.
• Controller: "Controller" is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether collection, evaluation, storage, transmission, or deletion.
• Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged, or sold. This data category is essential for the management and fulfilment of contractual obligations and 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, pricing arrangements, payment terms, termination rights, renewal options, and special terms or clauses. They serve as the legal basis for the relationship between the parties and are 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 of crucial importance for electronic commerce, online banking, and any other form of financial transaction. They contain details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers, and invoice information. Payment data may also contain information about payment status, chargebacks, authorisations, and fees.

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