Privacy Policy
1. Overview of Data Protection
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data includes all data that can personally identify you. Detailed information about data protection can be found in our privacy policy listed below this text.
Please also note the data protection information and privacy policy for applicants.
Data Collection on this Website
Who is responsible for data collection on this website?
The data processing on this website is carried out by the website operator. You can find their contact details in the “Controller Information” section of this privacy policy.
How do we collect your data?
Your data is collected when you provide it to us. This can be, for example, data you enter into a contact form.
Other data is automatically collected or with your consent when visiting the website by our IT systems. These mainly include technical data (e.g., internet browser, operating system, or time of page access). The collection of this data occurs automatically as soon as you enter this website.
How do we use your data?
Some of the data is collected to ensure the error-free provision of the website. Other data may be used for analyzing your user behavior.
What rights do you have regarding your data?
You have the right to obtain information about the origin, recipients, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent for data processing, you can revoke this consent at any time for the future. Additionally, under certain circumstances, you have the right to demand the restriction of processing your personal data. Furthermore, you have the right to lodge a complaint with the relevant supervisory authority.
You can contact us at any time for this purpose and for any further questions regarding data protection.
Analysis Tools and Third-Party Tools
When visiting this website, your browsing behavior may be statistically analyzed. This is mainly done using so-called analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy.
2. Hosting
We host the content of our website with the following providers:
All-Inkl
The provider is ALL-INKL.COM – Neue Medien Münnich, Inh. René Münnich, Hauptstraße 68, 02742 Friedersdorf (hereinafter All-Inkl). For details, please refer to the privacy policy of All-Inkl: https://all-inkl.com/datenschutzinformationen/.
The use of All-Inkl is based on Art. 6(1)(f) GDPR. We have a legitimate interest in providing a reliable representation of our website. If consent has been obtained, the processing is solely based on Art. 6(1)(a) GDPR and § 25(1) TTDSG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of TTDSG. The consent can be revoked at any time.
3. General Notes and Mandatory Information
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is information that can personally identify you. This privacy policy explains what data we collect and how we use it. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the Internet (e.g., when communicating via email) may have security vulnerabilities. Complete protection of data from access by third parties is not possible.
Note on the responsible entity
The responsible entity for data processing on this website is:
Comites GmbH
Dr. Andreas Föller
Jacobistraße 2
81927 Munich
Phone: +49 89 945485-30
E-Mail: andreas.foeller@comites.com
The responsible entity is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).
Storage Duration
Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for data processing ceases. If you assert a legitimate request for deletion or revoke consent for data processing, your data will be deleted, provided we have no other legally permissible grounds for retaining your personal data (e.g., tax or commercial retention periods); in the latter case, deletion will occur once these reasons no longer apply.
General Information on the Legal Basis for Data Processing on this Website
If you have given consent for data processing, we process your personal data based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data according to Art. 9(1) GDPR are processed. In case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), data processing is additionally based on § 25(1) TTDSG. The consent can be revoked at any time.
If your data is required for the performance of a contract or for pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR. Furthermore, we process your data if necessary to fulfill a legal obligation based on Art. 6(1)(c) GDPR. Data processing may also be based on our legitimate interest according to Art. 6(1)(f) GDPR. The relevant legal bases for data processing in each individual case will be provided in the following paragraphs of this privacy policy.
Note on Data Transfer to the USA and other Third Countries
We use tools from companies based in the USA or other countries that do not provide a level of data protection comparable to the EU. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to inform you that these countries may not guarantee a data protection level equivalent to that of the EU. For instance, US companies are obligated to disclose personal data to government authorities without the possibility for you as the data subject to challenge this legally. Therefore, it cannot be ruled out that US authorities (e.g., intelligence agencies) may process, analyze, and permanently store your data located on US servers for surveillance purposes. We have no control over these processing activities.
Revocation of Your Consent for Data Processing
Many data processing operations are only possible with your explicit consent. You can revoke consent that you have already given at any time. The lawfulness of data processing carried out before the revocation remains unaffected by the revocation.
Right to Object to Data Collection in Special Cases and Direct Marketing (Art. 21 GDPR)
IF DATA PROCESSING IS BASED ON ART. 6(1)(e) OR (f) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, INCLUDING PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS FOR PROCESSING CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING AT ANY TIME, INCLUDING PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, especially in the member state of their habitual residence, their place of work, or the place of the alleged infringement. This right to lodge a complaint is without prejudice to any other administrative or judicial remedies.
Right to Data Portability
You have the right to receive the data that we process automatically based on your consent or in fulfillment of a contract, in a common, machine-readable format, and to have it transferred to yourself or to a third party. If you request the direct transmission of the data to another controller, this will only be done to the extent technically feasible.
Information, Deletion, and Correction
You have the right, in accordance with applicable legal provisions, to obtain free information about your stored personal data, their origin and recipients, the purpose of data processing, and, if applicable, the right to correction or deletion of this data. For this and any further questions regarding personal data, you can contact us at any time.
Right to Restriction of Processing
You have the right to request the restriction of processing of your personal data. For this, you can contact us at any time. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. During the verification period, you have the right to request the restriction of processing of your personal data.
- If the processing of your personal data was/is unlawful, you can demand the restriction of data processing instead of deletion.
- If we no longer need your personal data, but you need it for exercising, defending, or asserting legal claims, you have the right to request the restriction of processing of your personal data instead of deletion.
- If you have objected pursuant to Art. 21(1) GDPR, a balancing of interests between your rights and ours must be carried out. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of processing of your personal data.
If you have restricted the processing of your personal data, these data may – apart from their storage – only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.
SSL/TLS Encryption
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator, this site uses SSL/TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the padlock symbol in your browser line.
4. Data Collection on this Website
Cookies
Our websites use so-called “cookies.” Cookies are small data packets that do not cause any damage to your device. They are either temporarily stored for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit ends. Persistent cookies remain stored on your device until you delete them manually or until your web browser automatically deletes them.
Cookies can be set by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies allow the integration of specific services from third-party companies within websites (e.g., cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used for analyzing user behavior or for advertising purposes.
Cookies that are necessary for carrying out the electronic communication process, providing certain functions you request (e.g., for the shopping cart function), or optimizing the website (e.g., cookies for measuring web audience) are stored based on Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent for storing cookies and similar tracking technologies has been requested, processing will be based exclusively on this consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG); the consent can be revoked at any time.
You can configure your browser settings to be informed about the placement of cookies, allow cookies only on a case-by-case basis, exclude the acceptance of cookies for specific cases or in general, and activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.
You can find information about the cookies and services used on this website in this privacy policy.
Consent with Borlabs Cookie
Our website uses the consent technology provided by Borlabs Cookie to obtain your consent for storing certain cookies in your browser or for using certain technologies in a privacy-compliant manner and to document this consent. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as “Borlabs”).
When you enter our website, a Borlabs cookie is stored in your browser, which stores the consents you have given or the revocation of these consents. This data is not transmitted to the provider of Borlabs Cookie.
The collected data will be stored until you request deletion or until the Borlabs cookie is deleted, or the purpose for data storage no longer applies. Mandatory legal retention periods remain unaffected. Details about the data processing of Borlabs Cookie can be found at https://en.borlabs.io/kb/what-data-does-borlabs-cookie-store/.
The use of Borlabs Cookie Consent technology is to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.
Server Log Files
The provider of the pages automatically collects and stores information in server log files, which your browser automatically transmits to us. This information includes:
- Browser type and version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
There is no consolidation of this data with other data sources.
The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of their website, for which the server log files need to be collected.
Contact Form
If you submit inquiries to us via the contact form, the information provided in the contact form, including the contact details you provide, will be stored for the purpose of processing the inquiry and in case of follow-up questions. We will not share this information without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR, if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if it has been requested; the consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after completing the processing of your inquiry). Mandatory legal provisions – especially retention periods – remain unaffected.
Inquiries via Email, Phone, or Fax
If you contact us via email, phone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed for the purpose of handling your request. We will not disclose this information without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if it has been requested; the consent can be revoked at any time.
The data you submit to us through contact inquiries will remain with us until you request us to delete it, revoke your consent for storage, or the purpose for data storage no longer exists (e.g., after completing the processing of your request). Mandatory legal provisions – especially retention periods – remain unaffected.
Typeform
We have integrated Typeform into this website. The provider is TYPEFORM S.L., Carrer Bac de Roda, 163, 08018 Barcelona, Spain (hereinafter referred to as Typeform).
Typeform allows us to create online forms and integrate them into our website. The data you enter into our Typeform forms will be stored on Typeform’s servers until you request us to delete it, revoke your consent for storage, or the purpose for data storage no longer exists (e.g., after completing the processing of your request). Mandatory legal provisions – especially retention periods – remain unaffected.
The use of Typeform is based on Art. 6(1)(f) of the GDPR. The website operator has a legitimate interest in functioning online forms. If appropriate consent has been obtained, the processing is exclusively based on Art. 6(1)(a) of the GDPR and § 25(1) of the TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Calendly
On our website, you have the opportunity to schedule appointments with us. For appointment booking, we use the tool “Calendly”. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA (hereinafter “Calendly”).
To schedule an appointment, enter the requested data and preferred date into the provided form. The entered data will be used for the planning, execution, and, if necessary, follow-up of the appointment. The appointment data will be stored on Calendly’s servers. You can view Calendly’s privacy policy here: https://calendly.com/de/pages/privacy.
The data you entered will remain with us until you request its deletion, revoke your consent for storage, or the purpose for data storage no longer exists. Mandatory legal provisions, especially retention periods, remain unaffected.
The legal basis for data processing is Art. 6(1)(f) of the General Data Protection Regulation (GDPR). The website operator has a legitimate interest in facilitating uncomplicated appointment scheduling with interested parties and customers. If the corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) of the GDPR and § 25(1) of the German Telemedia Act (TTDSG), provided that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
The data transfer to the USA is based on the European Commission’s Standard Contractual Clauses. Details can be found here: https://calendly.com/pages/dpa.
Bubble Group Inc.
Bubble Group Inc., 900 Broadway, Suite 504, New York (NY-10003), USA (Bubble), is a program for programming websites and apps as well as a cloud platform to operate these websites and apps. The data processing and storage utilize a server infrastructure provided by Bubble. Our data transfer with Bubble is regulated by the European Commission’s Standard Contractual Clauses (SCCs).
Bubble is responsible for the security of the underlying infrastructure. For more information on the terms of use and data protection of Bubble Group Inc., please visit the operator’s page.
Sendinblue GmbH
Sendinblue GmbH (Köpenicker Straße 126, 10179 Berlin) is a SaaS provider of online marketing solutions specializing in email marketing solutions. We use the SaaS solution from Sendinblue GmbH for GDPR-compliant email distribution to our users. Specifically, we send our users inspiring emails and reminders to use our services.
The technical and organizational measures (TOMs) of Sendinblue GmbH have been reviewed and certified by TÜV Rheinland. For more information on the data protection of Sendinblue GmbH, please visit the operator’s page.
HubSpot CRM
We use HubSpot CRM on this website. The provider is HubSpot Inc., 25 Street, Cambridge, MA 02141, USA (hereinafter referred to as HubSpot CRM).
HubSpot CRM allows us to manage existing and potential customers as well as customer contacts. With the help of HubSpot CRM, we can capture, organize, and analyze customer interactions via email, social media, or phone across various channels. The personal data collected in this way can be evaluated and used for communication with potential customers or for marketing activities (e.g., newsletter mailings). Additionally, with HubSpot CRM, we can track and analyze the user behavior of our contacts on our website.
The use of HubSpot CRM is based on Art. 6(1)(f) of the GDPR. The website operator has a legitimate interest in efficient customer management and communication. If a corresponding consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) of the GDPR and § 25(1) of the TTDSG, insofar as the consent includes the storage of cookies or the access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
Please refer to HubSpot’s privacy policy for details: https://legal.hubspot.com/de/privacy-policy.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. For details, please visit: https://www.hubspot.de/data-privacy/privacy-shield.
Registration on this website
You can register on this website to access additional features on the site. The data you enter for registration will only be used for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.
For important changes, such as changes to the scope of services or technically necessary modifications, we will use the email address provided during registration to inform you accordingly.
The processing of the data provided during registration is carried out for the purpose of fulfilling the contractual relationship established by the registration and, if applicable, for initiating further contracts (Art. 6(1)(b) of the GDPR).
The data collected during registration will be stored by us as long as you are registered on this website and will be deleted thereafter. Legal retention periods remain unaffected.
5. Social Media
Elements of the social network Facebook are integrated on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the USA and other third countries.
You can find an overview of the Facebook social media elements here: https://developers.facebook.com/docs/plugins/?locale=en_US.
If the social media element is active, a direct connection is established between your device and the Facebook server. As a result, Facebook receives the information that you have visited this website with your IP address. If you click on the Facebook “Like” button while logged into your Facebook account, you can link the content of this website to your Facebook profile. This allows Facebook to associate your visit to this website with your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the transmitted data or its use by Facebook. For more information, please refer to Facebook’s privacy policy at: https://www.facebook.com/privacy/explanation.
Where consent has been obtained, the use of the above-mentioned service is based on Art. 6(1)(a) of the General Data Protection Regulation (GDPR) and § 25 of the German Telemedia Act (TTDSG). Consent can be revoked at any time. Where no consent has been obtained, the use of the service is based on our legitimate interest in achieving comprehensive visibility on social media platforms.
To the extent that personal data is collected on our website using the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, jointly determine the purposes and means of this data processing (Art. 26 GDPR). The joint responsibility is limited solely to the collection of the data and its transmission to Facebook. The subsequent processing by Facebook after the data has been transmitted is not part of the joint responsibility. The obligations that are jointly incumbent upon us have been set out in an agreement on joint processing. You can find the wording of the agreement here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for the data protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of its products. You can exercise your rights as a data subject (e.g., requests for information) regarding the data processed by Facebook directly with Facebook. If you exercise your data subject rights with us, we are obliged to forward them to Facebook.
The data transfer to the USA is based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381, and https://www.facebook.com/policy.php.
This website incorporates features of the Instagram service, provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
If the social media element is active, a direct connection is established between your device and the Instagram server. Instagram thereby receives information about your visit to this website.
If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking the Instagram button. As a result, Instagram can associate the visit to this website with your user account. We would like to point out that as the provider of the pages, we do not have any knowledge of the content of the transmitted data or its use by Instagram.
If consent has been obtained, the use of the aforementioned service is based on Art. 6(1)(a) of the General Data Protection Regulation (GDPR) and § 25 of the German Telemedia Act (TTDSG). The consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in achieving the widest possible visibility on social media, pursuant to applicable regulations.
To the extent that personal data is collected on our website using the described tools and transmitted to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing under Article 26 of the General Data Protection Regulation (GDPR). The joint responsibility is limited solely to the collection of data and its transmission to Facebook or Instagram. The subsequent processing by Facebook or Instagram after transmission is not part of the joint responsibility. Our joint obligations have been documented in an agreement on joint processing. You can find the wording of the agreement at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook or Instagram tools and for the data protection-compliant implementation of the tools on our website. Facebook is responsible for the data security of the Facebook or Instagram products. If you wish to exercise your rights as a data subject (e.g., requests for information) with respect to data processed by Facebook or Instagram, you can directly contact Facebook. If you assert your data subject rights with us, we are obligated to forward them to Facebook.
The data transfer to the USA is based on the Standard Contractual Clauses of the European Commission. You can find details here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875, and https://de-de.facebook.com/help/566994660333381.
For more information, please refer to Instagram’s Privacy Policy: https://instagram.com/about/legal/privacy/.
This website uses elements from the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Every time you access a page on this website that contains elements from LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click the “Recommend” button of LinkedIn and are logged into your LinkedIn account, LinkedIn can associate your visit to this website with you and your user account. We would like to point out that as the provider of these pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn.
If consent has been obtained, the use of the aforementioned service is based on Art. 6(1)(a) GDPR and § 25 TTDSG. The consent can be revoked at any time. If no consent has been obtained, the use of the service is based on our legitimate interest in achieving the broadest possible visibility on social media.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. For details, please see: https://www.linkedin.com/help/linkedin/answer/62538/data-transfers-from-the-eu-eea-and-switzerland?lang=en.
For more information, please refer to the privacy policy of LinkedIn at: https://www.linkedin.com/legal/privacy-policy.
6. Analysis Tools and Advertising
Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
The Google Tag Manager is a tool that allows us to integrate tracking or analytics tools and other technologies on our website. The Google Tag Manager itself does not create user profiles, store cookies, or conduct independent analysis. It solely serves for the management and deployment of the tools integrated through it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The use of Google Tag Manager is based on Article 6(1)(f) of the General Data Protection Regulation (GDPR). The website operator has a legitimate interest in quickly and easily integrating and managing various tools on their website. If consent has been obtained, the processing is carried out exclusively based on Article 6(1)(a) of the GDPR and § 25(1) of the German Telemedia Act (TTDSG), to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined in the TTDSG. Consent can be revoked at any time.
Google Analytics
This website uses features of the web analytics service Google Analytics, provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics allows the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, duration of visit, operating systems used, and user origin. This data is assigned to the respective user’s device. However, no direct association is made with a user ID.
Furthermore, we can record your mouse and scroll movements, as well as clicks, using Google Analytics. Additionally, Google Analytics employs various modeling approaches to complement the collected data and utilizes machine learning technologies for data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). The information collected by Google regarding the use of this website is usually transferred to a server of Google in the United States and stored there.
The use of this service is based on your consent according to Art. 6(1)(a) GDPR and § 25(1) TTDSG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.
Browser Plugin
You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
You can find more information about how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.
Google Ads
The website operator uses Google Ads. Google Ads is an online advertising program provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads allows us to display advertisements on the Google search engine or on third-party websites when users enter certain search terms on Google (Keyword Targeting). Additionally, targeted ads can be displayed based on user data available at Google (e.g., location data and interests) (Audience Targeting). As a website operator, we can quantitatively evaluate this data by analyzing, for example, which search terms led to the display of our ads and how many clicks resulted from those ads.
The use of this service is based on your consent under Art. 6(1)(a) GDPR and § 25(1) TTDSG. The consent can be revoked at any time.
The data transfer to the USA is based on the Standard Contractual Clauses of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.
Google Ads Remarketing
This website uses the features of Google Ads Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign individuals who interact with our online offering to specific target groups in order to show them interest-based advertising in the Google advertising network (remarketing or retargeting).
Furthermore, the advertising target groups created with Google Ads Remarketing can be linked to the cross-device capabilities of Google. This allows interest-based, personalized advertising messages that have been tailored to your previous usage and browsing behavior on one device (e.g., mobile phone) to also be displayed on another of your devices (e.g., tablet or PC).
If you have a Google account, you can opt-out of personalized advertising by following this link: https://www.google.com/settings/ads/onweb/.
The use of this service is based on your consent according to Art. 6(1)(a) of the General Data Protection Regulation (GDPR) and § 25(1) of the Federal Data Protection Act (TTDSG). The consent can be revoked at any time.
Further information and the privacy policy can be found in Google’s privacy policy at: https://policies.google.com/technologies/ads?hl=de.
Customer Match for Audience Building
For audience building, we use Google Ads Remarketing’s Customer Match feature. In this process, we provide certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are Google users and logged into their Google accounts, they will see relevant advertising messages within the Google network (e.g., on YouTube, Gmail, or in the search engine).
Google Conversion Tracking
This website uses Google Conversion Tracking. The provider is Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Ireland.
Using Google Conversion Tracking, both Google and we can determine whether the user has performed certain actions. For instance, we can evaluate which buttons on our website are clicked most frequently and which products are viewed or purchased most frequently. This information is used to create conversion statistics. We learn the total number of users who clicked on our ads and the actions they took. We do not receive information that personally identifies the user. Google itself uses cookies or comparable recognition technologies for identification.
The use of this service is based on your consent according to Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG. Consent can be revoked at any time.
More information about Google Conversion Tracking can be found in Google’s Privacy Policy: https://policies.google.com/privacy?hl=de.
Meta Pixel (formerly Facebook Pixel)
This website uses the visitor action pixel of Facebook/Meta for conversion measurement. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the United States and other third countries.
This allows tracking of the behavior of website visitors after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables the effectiveness of Facebook ads to be evaluated for statistical and market research purposes and future advertising campaigns to be optimized.
The collected data is anonymous for us as the operator of this website; we cannot draw any conclusions about the identity of the users. However, Facebook stores and processes the data, allowing a connection to the respective user profile and enabling Facebook to use the data for its own advertising purposes in accordance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). As a result, Facebook can enable the display of ads on Facebook pages as well as outside of Facebook. This use of data cannot be influenced by us as the website operator.
The use of this service is based on your consent according to Art. 6 Para. 1 lit. a GDPR and § 25 Para. 1 TTDSG. The consent can be revoked at any time.
To the extent that personal data is collected on our website using the tool described here and transmitted to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of data and its transmission to Facebook. The processing carried out by Facebook after the data is transmitted is not part of the joint responsibility. Our joint obligations have been recorded in an agreement on joint processing. The wording of the agreement can be found here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for the data protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of its products. Rights of data subjects (e.g. requests for information) regarding data processed by Facebook can be exercised directly with Facebook. If you assert your data subject rights with us, we are obligated to forward them to Facebook.
Die Datenübertragung in die USA wird auf die Standardvertragsklauseln der EU-Kommission gestützt. Details finden Sie hier: https://www.facebook.com/legal/EU_data_transfer_addendum und https://de-de.facebook.com/help/566994660333381.
In the privacy notices of Facebook, you will find further information on the protection of your privacy: https://de-de.facebook.com/about/privacy/.
You can also deactivate the remarketing function “Custom Audiences” in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you need to be logged in to Facebook.
If you do not have a Facebook account, you can deactivate usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.
Facebook Conversion API
We have integrated the Facebook Conversion API on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the collected data is also transferred to the USA and other third countries.
The Facebook Conversion API allows us to capture the interactions of website visitors with our site and transmit them to Facebook in order to enhance advertising performance on Facebook.
For this purpose, we particularly collect the time of the visit, the visited webpage, your IP address, your user agent, and potentially other specific data (such as purchased products, cart value, and currency). A comprehensive overview of the collectable data can be found here: https://developers.facebook.com/docs/marketing-api/conversions-api/parameters.
The use of this service is based on your consent in accordance with Article 6(1)(a) of the GDPR and § 25(1) of the TTDSG. The consent can be revoked at any time.
To the extent that personal data is collected on our website and transmitted to Facebook using the tool described here, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Article 26 of the GDPR). However, this joint responsibility is limited solely to the collection of data and its transmission to Facebook. The processing carried out by Facebook after the transmission is not part of the joint responsibility. Our joint obligations have been defined in an agreement on joint processing. The wording of this agreement can be found here: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data protection information when using the Facebook tool and for the data protection-compliant implementation of the tool on our website. Facebook is responsible for the data security of its products. Data subject rights (e.g., requests for information) regarding data processed by Facebook can be exercised directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
In the data protection notes of Facebook, you will find further information regarding the protection of your privacy: https://de-de.facebook.com/about/privacy/.
Facebook Custom Audiences
We utilize Facebook Custom Audiences. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
When you visit or use our websites and apps, take advantage of our free or paid offers, transmit data to us, or interact with the Facebook content of our company, we collect your personal data in this process. If you grant us consent to use Facebook Custom Audiences, we will transmit this data to Facebook, which can then display relevant advertisements to you. Furthermore, your data can be used to define target groups (Lookalike Audiences).
Facebook processes these data as our data processor. Details can be found in Facebook’s Terms of Use for Custom Audiences: https://www.facebook.com/legal/terms/customaudience.
The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Your consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.facebook.com/legal/terms/customaudience and https://www.facebook.com/legal/terms/dataprocessing.
LinkedIn Insight Tag
This website uses the LinkedIn Insight Tag. The provider of this service is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Data Processing by LinkedIn Insight Tag
With the help of the LinkedIn Insight Tag, we receive information about the visitors to our website. If a website visitor is registered on LinkedIn, we can analyze, among other things, the professional details (e.g., career level, company size, country, location, industry, and job title) of our website visitors in order to better tailor our site to the respective target groups. Additionally, we can measure, using the LinkedIn Insight Tag, whether the visitors to our website make a purchase or take any other action (conversion measurement). The conversion measurement can also take place across devices (e.g., from PC to tablet). LinkedIn Insight Tag also offers a retargeting function that allows us to display targeted advertisements to website visitors outside of the website, with no identification of the recipient of the advertisement according to LinkedIn.
LinkedIn also collects so-called log files (URL, referrer URL, IP address, device and browser characteristics, and access time). The IP addresses are shortened or, if they are used to reach LinkedIn members across devices, hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data is then deleted within 180 days.
The data collected by LinkedIn cannot be attributed to specific individuals by us as the website operator. LinkedIn will store the collected personal data of website visitors on its servers in the USA and use them for its own advertising purposes. For details, please refer to LinkedIn’s Privacy Policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.
Legal Basis
Where consent has been obtained, the use of the aforementioned service is based solely on Art. 6 para. 1 lit. a GDPR and § 25 TTDSG. Consent can be revoked at any time. If no consent has been obtained, the use of this service is based on Art. 6 para. 1 lit. f GDPR; the website operator has a legitimate interest in effective advertising measures, including social media.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.
Objection to the Use of LinkedIn Insight Tag
You can object to the analysis of your usage behavior and targeted advertising by LinkedIn under the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Furthermore, LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To prevent the linking of data collected on our website by LinkedIn to your LinkedIn account, you must log out of your LinkedIn account before visiting our website.
Data Processing Agreement
We have concluded a contract for order processing (DPA) for the use of the above-mentioned service. This is a legally required contract that ensures that this service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
7. Newsletter
Newsletter Data
If you would like to subscribe to the newsletter offered on the website, we need an email address from you and information that allows us to verify that you are the owner of the specified email address and that you consent to receiving the newsletter. Further data will not be collected or will only be collected on a voluntary basis. We use newsletter service providers for the processing of newsletters, which are described below.
Mailchimp
This website uses the services of Mailchimp for sending newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
Mailchimp is a service that facilitates the organization and analysis of, among other things, newsletter distribution. If you enter data for the purpose of subscribing to the newsletter (e.g., email address), this data will be stored on Mailchimp’s servers in the USA.
Using Mailchimp, we can analyze our newsletter campaigns. When you open an email sent with Mailchimp, a file contained in the email (known as a web beacon) connects to Mailchimp’s servers in the USA. This allows us to determine whether a newsletter message has been opened and which links have potentially been clicked. Additionally, technical information is collected (such as the time of access, IP address, browser type, and operating system). This information cannot be attributed to the respective newsletter recipient. It is solely used for statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of recipients.
If you do not wish to have your data analyzed by Mailchimp, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.
Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of processing activities carried out prior to the revocation remains unaffected.
The data you provided to us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter. After unsubscribing, your data will be deleted from the newsletter distribution list. Data that has been stored for other purposes with us remains unaffected by this.
Data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.
After you have been removed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if necessary to prevent future mailings. Data from the blacklist is only used for this purpose and is not merged with other data. This serves both your interests and our interests in complying with legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is not time-limited. You can object to this storage if your interests outweigh our legitimate interest.
For more information, please refer to the privacy policy of Mailchimp: https://mailchimp.com/legal/terms/.
8. Plugins and Tools
YouTube with Enhanced Privacy Mode
This website embeds videos from the YouTube website. The operator of these pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in the enhanced privacy mode. According to YouTube, this mode ensures that YouTube does not store information about visitors to this website before they watch the video. However, data sharing with YouTube partners is not necessarily excluded by the enhanced privacy mode. Therefore, YouTube establishes a connection to the Google DoubleClick network regardless of whether you are watching a video.
When you start a YouTube video on this website, a connection to YouTube’s servers is established. The YouTube server is informed about which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to directly associate your browsing behavior with your personal profile. You can prevent this by logging out of your YouTube account.
Furthermore, after starting a video, YouTube may store various cookies on your device or use similar recognition technologies (such as device fingerprinting). This allows YouTube to gather information about visitors to this website. This information is used, among other things, to capture video statistics, improve user-friendliness, and prevent fraud attempts.
If you start a YouTube video, additional data processing operations may be triggered, over which we have no control.
The use of YouTube is in the interest of presenting our online offerings in an appealing manner. This constitutes a legitimate interest pursuant to Art. 6(1)(f) of the GDPR. If a corresponding consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) of the GDPR and § 25(1) of the TTDSG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) in the sense of the TTDSG. The consent can be revoked at any time.
For more information about privacy at YouTube, please refer to their privacy policy at: https://policies.google.com/privacy?hl=en.
Google Fonts (Local Hosting)
This site uses so-called Google Fonts for the uniform display of fonts, provided by Google. The Google Fonts are installed locally. There is no connection to Google’s servers.
For more information about Google Fonts, please visit https://developers.google.com/fonts/faq and consult Google’s privacy policy: https://policies.google.com/privacy?hl=en.
Wordfence
We have integrated Wordfence on this website. The provider is Defiant Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).
Wordfence is used to protect our website from unwanted access or malicious cyberattacks. For this purpose, our website establishes a persistent connection to Wordfence’s servers, allowing Wordfence to synchronize its databases with the accesses made on our website and, if necessary, block them.
The use of Wordfence is based on Article 6(1)(f) of the GDPR. The website operator has a legitimate interest in effectively protecting the website from cyberattacks. If corresponding consent has been obtained, the processing is carried out exclusively on the basis of Article 6(1)(a) of the GDPR and § 25(1) TTDSG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
The data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.
9. eCommerce and Payment Providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data for the establishment, content design, and modification of our contractual relationships. We only collect, process, and use personal data about the use of this website (usage data) to the extent necessary to enable the user to access or charge for the service. The legal basis for this is Article 6(1)(b) of the GDPR.
The collected customer data will be deleted after completion of the order or termination of the business relationship and after any statutory retention periods have expired. Statutory retention periods remain unaffected.
Data Transmission upon Conclusion of Contracts for Services and Digital Content
We only transmit personal data to third parties if this is necessary within the scope of contract processing, for example to the credit institution commissioned with payment processing.
Further transmission of the data does not occur or only if you have explicitly consented to the transmission. Your data will not be disclosed to third parties without your explicit consent, for example for advertising purposes.
The legal basis for data processing is Article 6(1)(b) of the GDPR, which allows the processing of data for the fulfillment of a contract or pre-contractual measures.
10. Audio and Video Conferences
Data Processing
For communication with our customers, among other tools, we use online conferencing tools. The tools we use are listed below. When you communicate with us via video or audio conference over the internet, your personal data is collected and processed by us and the provider of the respective conference tool.
The conference tools collect all data that you provide/use to use the tools (email address and/or your phone number). Additionally, the conference tools process the duration of the conference, start and end times (time) of participation in the conference, number of participants, and other “context information” related to the communication process (metadata).
Furthermore, the provider of the tool processes all technical data necessary for the online communication process. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.
If content is exchanged, uploaded, or otherwise provided within the tool, it is also stored on the servers of the tool providers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards, and other information shared during the use of the service.
Please note that we do not have full control over the data processing operations of the tools used. Our capabilities are largely determined by the corporate policies of the respective providers. Further information on data processing by the conference tools can be found in the privacy policies of the tools used, which are listed below this text.
Purpose and Legal Bases
The conference tools are used to communicate with prospective or existing contract partners or to offer certain services to our customers (Article 6(1)(b) GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Article 6(1)(f) GDPR). If consent has been obtained, the relevant tools are used based on this consent; the consent can be revoked at any time with effect for the future.
Storage Duration
The data directly collected by us through video and conference tools will be deleted from our systems as soon as you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory legal retention periods remain unaffected.
Regarding the storage duration of your data that is stored by the operators of the conference tools for their own purposes, we have no influence. For details on this, please refer directly to the operators of the conference tools.
Utilized Conference Tools
We use the following conference tools:
Zoom
We use Zoom. The provider of this service is Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. Details on data processing can be found in Zoom’s Privacy Policy: https://zoom.us/de-de/privacy.html.
The data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://zoom.us/de-de/privacy.html.
Microsoft Teams
We use Microsoft Teams. The provider of this service is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Details on data processing can be found in the Privacy Statement of Microsoft Teams: https://privacy.microsoft.com/de-de/privacystatement.
© 2024 Comites GmbH.
All rights reserved.
© 2023 Comites GmbH. All rights reserved.