Privacy Policy

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also referred to as "data") we process, for which 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 the "online offering").

The terms used are not gender-specific.

WolfNex AI
Theodor-Heuss-Strasse 28a
38444 Wolfsburg, Germany

Authorised representative: Maximilian Arefjev

Email address: info@wolfnex-ai.de

Telephone: +49 1520 5932570, +49 178 8222903

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

Types of data processed

• 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 management procedures.

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 requirements may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in an individual case, we will inform you of these in this privacy policy.

• Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of personal data relating to them for one or more specific purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

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

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as the access to, input, disclosure, availability and separation of the data. We have also established procedures that ensure the exercise of data subject rights, the erasure of data, and responses to threats to the data. Furthermore, 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 by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services against 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), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transfers meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL, signalling to users that their data is transmitted securely and encrypted.

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

Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be identified from the postal address of the respective provider, or where this privacy policy expressly refers to a data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA we rely primarily on the Data Privacy Framework (DPF), which was 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 twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as additional security. Should changes arise in connection with the DPF, the standard contractual clauses take effect as a reliable fallback. This ensures that your data always remains adequately protected, even in the event of political or legal changes.

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

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent, or transfers required by law. 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.

We erase personal data that we process in accordance with the statutory provisions as soon as the underlying consent is withdrawn or no further legal bases for the processing exist. 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 where statutory obligations or particular 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 proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

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

Where several statements are made about the retention period or erasure deadlines for a piece of data, the longest period always applies. Data that is no longer retained for the originally intended purpose but on the basis of legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

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

• 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the working instructions and other organisational documents required to understand them (Section 147(1) no. 1 in conjunction with (3) AO, Section 14b(1) UStG, Section 257(1) no. 1 in conjunction with (4) HGB).
• 8 years – accounting vouchers such as invoices and expense receipts (Section 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257(1) no. 4 in conjunction with (4) HGB).
• 6 years – other business documents: commercial or business letters received, copies of commercial or business letters sent, and other documents insofar as they are relevant for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labelling, and also payroll accounting documents insofar as they are not already accounting vouchers, and till rolls (Section 147(1) nos. 2, 3, 5 in conjunction with (3) AO, Section 257(1) nos. 2 and 3 in conjunction with (4) HGB).
• 3 years – data required in order to take account of potential warranty and damages claims or similar contractual claims and rights, and to process related enquiries, based on past business experience and customary industry practice, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Periods beginning at the end of the year: Where a period does not expressly begin on a specific date and lasts at least one year, it starts automatically at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the point at which the termination takes effect or the legal relationship otherwise ends.

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

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

We process 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, performance and settlement of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular to fulfil our primary and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty claims and other performance issues, the processing of withdrawals, terminations of continuing obligations, reversals and refunds, as well as the handling of other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.

In particular, we process master data such as name, address and, where applicable, company, contact data such as email address and telephone number, contract and service data such as the subject matter of the contract, contract term, order or transaction number, usage and performance data, payment and billing data, as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in the course of performing an order.

In addition, we process the data to protect our rights and to fulfil legal obligations. This includes in particular commercial and tax law retention obligations, documentation obligations and, where applicable, evidence and accountability obligations. Processing also takes place 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 and from threats to data, trade secrets and other legally protected interests. This may also involve engaging external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers, or other agents, insofar as this is necessary for the performance of the contract or to fulfil legal obligations.

Personal data is disclosed to third parties only insofar as this is necessary for the performance of the contract, for pre-contractual measures, to safeguard legitimate interests, or to fulfil legal obligations. We provide separate information within this privacy policy about any processing that goes beyond this, in particular for marketing purposes.

We inform contractual partners which data is required in the individual case when the data is collected, for example in online forms by means of corresponding labelling, or in personal contact.

The data is erased as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent this. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the course of a specific order is erased after completion of the order and expiry of any retention periods, unless further legal or contractual storage obligations exist.

The legal basis for the processing is Art. 6(1)(b) GDPR for pre-contractual measures and the performance of the respective contractual relationship, and Art. 6(1)(c) GDPR for the fulfilment of legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves our legitimate interests in a 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, preventing misuse and fraud, and the economic management and further development of our business. These interests consist in particular in ensuring secure and legally compliant business operations and in preserving our ability to act as a company.

• 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 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; communication; office and organisational procedures; organisational and administrative procedures; business processes and management procedures.
• Retention and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
• Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services

• Agency services: We process the data of our customers within the scope of our contractual services, which may include, for example, 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 enquiries (Art. 6(1)(b) GDPR).
• Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the chosen services or works and associated activities, as well as their payment and provision, execution or performance. The required information is identified as such in the course of the order, purchase or comparable conclusion of contract and comprises the information required for the provision of services and billing, as well as contact information in order to be able to hold any consultations. Insofar as we obtain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal bases: performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

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 in order 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, 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); log data (e.g. log files concerning logins or the retrieval of data, or access times); content data (e.g. textual or pictorial messages and contributions and the information relating to them, such as details of 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; provision of contractual services and fulfilment of contractual obligations.
• Retention and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services

• Provision of the online offering on rented storage space: For the provision of our online offering we use storage space, computing capacity and software which we rent or otherwise obtain from a corresponding server provider (also referred to as a "web host"); legal bases: legitimate interests (Art. 6(1)(f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful retrieval, 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. Server log files may be used for security purposes, e.g. to avoid server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilisation and stability; legal bases: legitimate interests (Art. 6(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is necessary for evidentiary purposes is exempt from erasure until the respective incident has been finally clarified.
• Email dispatch and hosting: The web hosting services we use also cover the sending, receipt and storage of emails. For these purposes, the addresses of the recipients and senders, further information concerning the email dispatch (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of emails between the sender and receipt on our server; legal bases: legitimate interests (Art. 6(1)(f) GDPR).
• 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.ionos.de; privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; data processing agreement: Data processing agreement with IONOS.

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies may be used for a variety of purposes, such as the functionality, security and convenience of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with the statutory provisions. Where required, we obtain users' consent in advance. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is strictly necessary in order 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 withdrawn at any time. We provide clear information about its scope and which cookies are used.

Cookies used on this website: We currently do not use any cookies for analytics, tracking, advertising or reach measurement purposes, and we do not integrate any corresponding third-party services. Two cookies are technically necessary: one for your language selection (name: "NEXT_LOCALE"), which remembers whether you view the website in German or English, and one for your cookie decision (name: "wolfnex_consent", storage period six months). Neither contains an identifier that identifies you beyond these purposes, and neither is used to analyse your behaviour. You can delete them at any time via your browser settings; the website will continue to work and will ask for your cookie decision again.

Consent management: For consent-requiring cookies in the "Statistics" and "Marketing" categories, we obtain your consent via a consent banner before the corresponding services are loaded. Without your consent, no script in these categories is executed and no associated cookie is set; refusing is just as easy as agreeing. We store your decision in the "wolfnex_consent" cookie mentioned above – together with the version of the notice, the time, a random reference number and your consent per category. We log the same information on our server in order to be able to demonstrate consent in accordance with Art. 7(1) GDPR; your IP address is not stored in the process. You can change or withdraw your decision at any time via the "Cookie settings" link in the footer of every page. If you withdraw a category, we delete the associated cookies and reload the page so that the affected services do not continue to run. Withdrawal takes effect for the future and does not affect the lawfulness of processing carried out up to the point of withdrawal.

Notes on the data protection legal bases: Whether we process personal data using cookies depends on consent. Where consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures. Storing the language cookie and the consent cookie is strictly necessary to provide the service you have expressly requested (Section 25(2) no. 2 TDDDG) and therefore does not require consent.

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 saved and preferred content displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw the consent they have given at any time and can also object to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

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

When you contact us (e.g. by post, contact form, email, telephone or via social media), as well as 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 measures requested.

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions and the information relating to them, such as details of authorship or time of creation); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form); provision of our online offering and user-friendliness.
• Retention and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing operations, procedures and services

• Contact form: When you contact us via our contact form, by email or by other means of communication, we process the personal data transmitted to us in order to respond to and handle the respective matter. This generally includes information such as name, contact details and, where applicable, further information provided to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; legal bases: performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
• Resend (delivery of form messages): The information submitted via our contact form (name, email address, optionally company and telephone number, and your message) is delivered to our mailbox via the email delivery service Resend. The provider processes this data on our behalf; this involves a transfer to the USA, which is safeguarded by the measures described in the section "International data transfers"; service provider: Resend, Inc., San Francisco, California, USA; legal bases: performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR); website: https://resend.com; privacy policy: https://resend.com/legal/privacy-policy.

On this website we offer a chat assistant that answers questions about our services automatically. The assistant is an AI system and not a human being; we point this out in the chat window before you send your first message. Detailed information on our use of AI can be found in our AI transparency notice.

When you use the assistant, we transmit the content of your messages and the conversation history so far to our service provider NVIDIA, which operates the underlying language model and generates the response. This involves a transfer to the USA, which is safeguarded by the measures described in the section "International data transfers". Using the assistant is voluntary – you can reach us at any time via the contact form, by email or by telephone.

Please do not enter any sensitive personal data in the chat, in particular no health data, credentials or payment information. The conversation history is held in your browser only for the duration of your session and is not stored permanently by us or linked to a user account. To prevent misuse (limiting the number of requests per period), we additionally process your IP address temporarily; this information is not transmitted to the model provider and is automatically discarded after a short time.

The assistant does not make any automated decision within the meaning of Art. 22 GDPR that produces legal effects concerning you or similarly significantly affects you, and does not create a profile about you.

• Types of data processed: Content data (your chat messages and the conversation history); meta, communication and procedural data (e.g. IP address, timestamps).
• Data subjects: Users (e.g. website visitors, users of online services); prospective customers.
• Purposes of processing and legitimate interests: Communication; answering enquiries about our services; provision of our online offering and user-friendliness; security measures (prevention of misuse).
• Retention and erasure: Chat content is not stored permanently by us. The IP address processed to prevent misuse is automatically discarded after a short time. In all other respects, the information in the section "General information on data storage and erasure" applies.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR) in answering enquiries and in the secure operation of the offering; performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) insofar as your enquiry serves to initiate a contract.

Further information on processing operations, procedures and services

• NVIDIA (language model for the chat assistant): Provision of a large language model via a programming interface, which generates the responses of our chat assistant; service provider: NVIDIA Corporation, 2788 San Tomas Expressway, Santa Clara, CA 95051, USA; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.nvidia.com; privacy policy: https://www.nvidia.com/en-us/about-nvidia/privacy-policy/; basis for third-country transfers: safeguarded by the measures described in the section "International data transfers".

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 in this context. This may result in risks for users, because, for example, the enforcement of users' 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 on the basis of users' usage behaviour and the resulting interests. These profiles may in turn be used to place advertisements within and outside the networks that presumably correspond to users' interests. For this reason, cookies are generally stored on users' computers, in which the usage behaviour and interests of users are stored. In addition, data may also be stored in the usage profiles independently 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 description of the respective forms of processing and the options to object (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, 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 contributions and the information relating to them, such as details of authorship or time of creation); 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).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via an online form); public relations.
• Retention and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services

• Instagram: Social network that enables the sharing of photos and videos, commenting on and favouriting posts, sending messages, and subscribing to profiles and pages; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com; privacy policy: https://privacycenter.instagram.com/policy/; basis for third-country transfers: Data Privacy Framework (DPF).

We ask you to inform yourself regularly about the content of our privacy policy. We adapt 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 an act of cooperation on your part (e.g. consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and we ask you to check the details before making contact.

This section provides an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their statutory definitions apply. The following explanations are primarily intended to aid understanding.

• Employees: Employees are persons in an employment relationship, whether as staff, salaried employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It involves the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various phases, including its establishment, when the employment contract is concluded, its performance, when the employee carries out their work, and its termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance appraisals.
• Master data: Master data comprises essential information required for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic details 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 unambiguous assignment and communication.
• Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content 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 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: These are categories containing information about how data is processed, transmitted and managed. Metadata, also known as data about data, comprises information describing the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organisations, including workflow documentation, records of transactions and activities, and audit logs used to trace and verify operations.
• Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data covers a broad range of information showing how users use applications, which functions they prefer, how long they stay on particular pages, and which paths they take through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Usage data also plays a decisive 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 recorded 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 analyse system problems, for security monitoring or to produce performance reports.
• Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collection, analysis, storage, transmission or erasure.
• 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 category of data is essential for the administration and fulfilment of contractual obligations and covers both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, 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 decisive for clarifying rights and obligations, enforcing claims and resolving disputes.
• Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of decisive importance 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 invoice information. Payment data may also contain information about payment status, chargebacks, authorisations and fees.

Base text created with the free Datenschutz-Generator.de by Dr. Thomas Schwenke.