Privacy Policy

Preamble

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

The terms used are not gender-specific.

Last updated: April 15, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Representative in the European Union
• Applicable Legal Bases
• Security Measures
• Transfer of Personal Data
• International Data Transfers
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Provision of the Online Offering and Web Hosting
• Use of Cookies
• Contact and Inquiry Management
• Web Analytics, Monitoring and Optimisation
• Presences in Social Networks (Social Media)
• Changes and Updates
• Definitions

Controller

Soraton
Eichbergerstrasse 60
9452 Hinterforst
Switzerland

Authorised representatives: Robert Abbrederis

Email address: info@soraton.com

Legal notice: soraton.com/impressum

Representative in the European Union

Overview of Processing Activities

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

Types of Data Processed

• Contact data.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of Data Subjects

• Communication partners.
• Users.

Purposes of Processing

• Provision of contractual services and fulfilment of contractual obligations.
• Communication.
• Security measures.
• Audience measurement.
• Remarketing.
• Conversion measurement.
• Organisational and administrative procedures.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.
• Public relations.

Applicable Legal Bases

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

• Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

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

Security Measures

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

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability and segregation thereof. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and responses to data threats. In addition, we take the protection of personal data into account from the outset in 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 through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorised access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transfer of Personal Data

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

International Data Transfers

Data processing in third countries: 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 the use of third-party services or the disclosure or transfer of data to other persons, entities or companies (which becomes apparent from the postal address of the respective provider or when expressly referred to in the privacy policy as a data transfer to third countries), this is always done in accordance with the legal requirements.

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

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

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

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

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

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

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

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

For data transfers to other third countries, corresponding security measures apply, including international agreements, specific guarantees, Standard Data Protection Clauses approved by the FDPIC, or internal corporate data protection regulations recognised in advance by the FDPIC or a competent data protection authority of another country.

General Information on Data Storage and Deletion

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

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

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

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

Data retention and deletion: The following general deadlines apply to retention and archiving under Swiss law:

• 10 years – Retention period for books and records, annual accounts, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
• 10 years – Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for handling related enquiries, based on past business experience and standard industry practices, are stored for the duration of the statutory limitation period of ten years, unless a shorter period of five years applies, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest and other periodic payments, for the supply of foodstuffs, for board and lodging and for innkeepers’ debts, as well as for tradesmen’s work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries, and employment relationships of employees, become time-barred after five years (Art. 128 CO).

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

Rights of Data Subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consent given at any time.
• Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed and to obtain information about such data as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, to request 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 that 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.
• Complaint to a supervisory authority: In accordance with the legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you are entitled to the following rights under the Swiss DPA:

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

Provision of the Online Offering and Web Hosting

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved); Log data (e.g. log files relating to logins or data retrieval or access times). Content data (e.g. textual or visual messages and contributions as well as information relating thereto, 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 deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

• Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also 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, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure the utilisation and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally resolved.
• Rackspeed: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: rackSPEED GmbH, Reisholzer Werftstrasse 31b / Entrance 35, 40589 Duesseldorf, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://rackspeed.de/; Privacy policy: https://rackspeed.de/datenschutz/. Data processing agreement: Provided by the service provider.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies may also be used for various 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 legal requirements. Where necessary, we obtain the prior consent of users. If consent is not required, we rely on our legitimate interests. This applies where the storage and reading of information is indispensable for providing expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent may be revoked at any time. We provide clear information about the scope of cookies used and which cookies are utilised.

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

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

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the device has been closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, user data collected with the help of cookies may be used for audience measurement purposes. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage duration may be up to two years.

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

Cookie settings/objection option:

• 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).

Further information on processing activities, procedures and services:

• Processing of cookie data based on consent: We use a consent management solution in which the consent of users to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, the consent of users to the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, is obtained. Users also have the option to manage and revoke their consent. The consent declarations are stored in order to avoid having to repeat the query and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, the details of the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, system and device used; Legal bases: Consent (Art. 6(1)(a) GDPR).
• BorlabsCookie: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of data protection and cookie notices, enabling the revocation or adjustment of consents by users; Service provider: Operated on servers and/or computers under own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language, as well as types of consents and the time of their submission are stored server-side and in the cookie on the user’s device.

Contact and Inquiry Management

When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as in the context 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 visual messages and contributions as well as information relating thereto, such as details of authorship or time of creation). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Communication partners.
• Purposes of processing and legitimate interests: Communication; Organisational and administrative procedures; Feedback (e.g. collecting feedback via online forms). Provision of our online offering and user-friendliness.
• Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing activities, procedures and services:

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

Web Analytics, Monitoring and Optimisation

Web analytics (also referred to as “audience measurement”) is used to evaluate visitor flows of our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of audience analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used, or invite reuse. Likewise, we are able to identify which areas require optimisation.

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

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

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. In general, no clear-text data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but rather pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

• Types of data processed: Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Audience measurement (e.g. access statistics, identification of returning visitors); Profiles with user-related information (creation of user profiles); Provision of our online offering and user-friendliness; Remarketing; Conversion measurement (measurement of the effectiveness of marketing measures). Marketing.
• Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

• Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to assign analytics information to a device in order to identify which content users have accessed within one or more usage sessions, which search terms they have used, have revisited, or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers.
  Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based equivalents). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
• Information on consent recipients and cookieless analytics: Information on consent recipients: The consent given by users in the context of a consent dialogue (also known as “cookie opt-in/consent”, “cookie banner”, etc.) serves several purposes. Firstly, it serves us in fulfilling our obligation to obtain consent for the storage and reading of information on and from the user’s device (in accordance with ePrivacy Directives). Secondly, it covers the processing of personal data of users in accordance with data protection requirements. Furthermore, this consent also applies to Google, as the company is required under the Digital Markets Act to obtain consent for personalised services. Therefore, we share the status of user-granted consents with Google. Our consent management software informs Google whether consents have been granted or not. The aim is to ensure that the consents granted or not granted by users are taken into account when using Google Analytics and when integrating functions and external services. This allows user consents and their revocation to be dynamically adjusted within the framework of Google Analytics and other Google services in our online offering, depending on the user’s selection.
  Cookieless analytics: We use the advanced implementation of Google Analytics consent mode. This means that if users do not consent to the storage and reading of information on their devices – in particular regarding cookies – no cookies or comparable information will be stored on users’ devices. Likewise, no user profiles will be created.
  In this case, the Google code generates a random identification number on the user’s device and transmits it to Google (so-called “ping”). The identification is not stored in the browser, in apps or on other user devices. This identification number is unique to each website visit, so that the behaviour or interests of users cannot be tracked across devices or pages. Only a minimum of information about user activity is sent. This includes details about the consent status and information for conversion measurement, i.e. whether a user was directed to our online offering via a Google advertisement.
  Additionally, where available, the following information may be transmitted: a) Functional information such as headers (technical details transmitted by the browser), b) timestamps (date and time of access), c) user agent (information about the browser and device used, web only), d) referrer URL (the URL of the page from which the user came), e) aggregated/pseudonymous information: This includes an indication of whether the current or a previous page in the user’s navigation history contains information about the ad click in the URL (e.g. GCLID/DCLID, specific Google tracking codes), a random number generated on each page load, and information about the consent management platform used by the website owner (e.g. developer ID); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de. Privacy policy: https://policies.google.com/privacy.
• Google Tag Manager: We use Google Tag Manager, software by Google, which enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that serve to record and analyse visitor activities. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, does not store cookies with user profiles and does not carry out independent analyses. Its function is limited to simplifying and making more efficient the integration and management of tools and services that we use on our website. However, when using Google Tag Manager, the IP address of users is transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in the process. However, this data processing only occurs when services are integrated via Tag Manager. For more detailed information about these services and their data processing, we refer you to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data processing agreement:
  https://business.safety.google/adsprocessorterms. Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms).

Presences in Social Networks (Social Media)

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

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

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

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

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

• Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as information relating thereto, such as details of authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online forms). Public relations.
• Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.
• Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

• LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they take. In addition, details about the devices used are recorded, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles such as job function, country, industry, seniority level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
  We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which in particular governs the security measures that LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users may, for example, submit requests for information or deletion directly to LinkedIn). The rights of users (in particular the right of access, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: EU/EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa), Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Changes and Updates

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

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

Definitions

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

• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data may include 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, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
• Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure used to determine the effectiveness of marketing measures. For this purpose, a cookie is generally stored on users’ devices within the websites on which the marketing measures take place and then retrieved on the target website. For example, this allows us to track whether the advertisements we placed on other websites were successful.
• Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details about file size, creation date, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email correspondence, 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, transaction and activity logs, as well as audit logs used for tracking and reviewing operations.
• Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data encompasses a broad range of information showing how users use applications, which features they prefer, how long they spend on certain pages and through which paths they navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, encompasses any kind of automated processing of personal data that consists of using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are frequently used for profiling purposes.
• Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for analysing system problems, security monitoring or creating performance reports.
• Audience measurement: Audience measurement (also referred to as web analytics) is used to evaluate visitor flows of an online offering and may include the behaviour or interests of visitors in certain information, such as website content. With the help of audience analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This enables them, for example, to better tailor the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience measurement purposes in order to identify returning visitors and thus obtain more precise analyses of the use of an online offering.
• Remarketing: “Remarketing” or “retargeting” refers to the practice whereby, for example, for advertising purposes, it is noted which products a user was interested in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
• Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, whether it is collection, evaluation, storage, transmission or deletion.