Privacy Police

 

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 the “Online Offering”).
The terms used are not gender-specific.
As of: 17 February 2026

Table of Contents

  • Preamble

  • Controller

  • Overview of Processing Activities

  • Applicable Legal Bases

  • Security Measures

  • Transfer of Personal Data

  • International Data Transfers

  • General Information on Data Storage and Deletion

  • Rights of Data Subjects

  • Business Services

  • Payment Procedures

  • Provision of the Online Offering and Web Hosting

  • Use of Cookies

  • Contact and Enquiry Management

  • Surveys and Questionnaires

  • Web Analysis, Monitoring and Optimisation

  • Presences in Social Networks (Social Media)

  • Plug-ins and Embedded Functions and Content

  • Amendment and Updating

  • Definitions

Controller

Jennifer Margraff
Gildestraat 8
9000 Ghent
Belgium

Authorised Representative: Jennifer Margraff
E-mail address: hello@manushya.life
Legal Notice: https://manushya.life/impressum

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

  • Master data

  • Payment data

  • Contact data

  • Content data

  • Contract data

  • Usage data

  • Meta, communication and procedural data

  • Log data

Categories of Data Subjects

  • Service recipients and clients

  • Prospective customers

  • Communication partners

  • Users

  • Business and contractual partners

  • Participants

Purposes of Processing

  • Provision of contractual services and fulfilment of contractual obligations

  • Communication

  • Security measures

  • Reach measurement

  • Office and organisational procedures

  • Conversion measurement

  • Organisational and administrative procedures

  • Server monitoring and error detection

  • Feedback

  • Surveys and questionnaires

  • Profiles with user-related information

  • Provision of our Online Offering and user-friendliness

  • Information technology infrastructure

  • Public relations

  • Business processes and business management procedures

Applicable Legal Bases

Applicable legal bases under the GDPR: In the following, you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Should more specific legal bases be applicable in individual cases, we will inform you of these in this Privacy Policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of personal data relating to them for one or more specific purposes.

  • Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security Measures

We implement appropriate technical and organisational measures in accordance with statutory requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security 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 to, input of, disclosure of, safeguarding of availability of, and segregation of such data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data breaches. In addition, we take into account the protection of personal data already during 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):
In order to protect users’ data transmitted via our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. If 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 transmitted securely and in encrypted form.

Transfer of Personal Data

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

International Data Transfers

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

For data transfers to the United States, we primarily rely on the Data Privacy Framework (DPF), which has been recognised as a secure legal framework by an adequacy decision of the European Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the European Commission and establish contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection of your data: the DPF constitutes the primary level of protection, while the Standard Contractual Clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the Standard Contractual Clauses will act as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of 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/ (in English).

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

General Information on Data Storage and Deletion

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

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

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

Where multiple retention periods or deletion deadlines are specified for a given set of data, the longest period shall always apply. Data which is no longer required for the originally intended purpose but is retained due to statutory requirements or other reasons shall be processed exclusively for the reasons justifying its retention.

Commencement of Time Limits at the End of the Year:
Where a time limit does not expressly commence on a specific date and is at least one year in duration, it shall automatically commence at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the time limit shall be the effective date of termination or other cessation of the legal relationship.

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, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

·        Right to Withdraw Consent:
You have the right to withdraw any consent given at any time.

·        Right of Access:
You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the statutory provisions.

·        Right to Rectification:
In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

·        Right to Erasure and Restriction of Processing:
In accordance with the statutory provisions, 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.

·        Right to Data Portability:
You have the right to receive the data concerning you which you have provided to us in a structured, commonly used and machine-readable format or to request its transmission to another controller in accordance with the statutory provisions.

·        Right to Lodge a Complaint with a Supervisory Authority:
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Business Services

We process the data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “Contractual Partners”), within the scope of contractual and comparable legal relationships as well as related measures and with regard to communication with the Contractual Partners (or pre-contractually), for example in order to respond to enquiries.

We use this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations, and remedies in the event of warranty claims or other service disruptions. Furthermore, we use the data to safeguard our rights and for the purposes of administrative tasks associated with these obligations as well as for company organisation. In addition, we process the data on the basis of our legitimate interests in both proper and efficient business management and in security measures to protect our Contractual Partners and our business operations against misuse, endangerment of their data, secrets, information, and rights (e.g. involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers, or financial authorities). Within the scope of applicable law, we disclose the data of Contractual Partners to third parties only to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations. Contractual Partners will be informed of further forms of processing, for example for marketing purposes, within the scope of this Privacy Policy.

We inform the Contractual Partners prior to or in the course of data collection which data is required for the aforementioned purposes, for example in online forms by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, for example for as long as it must be retained for statutory archiving reasons (e.g. for tax purposes, generally ten years). Data disclosed to us by the Contractual Partner in the context of an order shall be deleted in accordance with the requirements and generally upon completion of the order.

·        Categories of Data Processed:
Master data (e.g. full name, residential address, contact details, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and e-mail addresses or telephone numbers); contractual data (e.g. subject matter of the contract, term, customer category).

·        Data Subjects:
Service recipients and clients; prospective customers; business and contractual partners.

·        Purposes of Processing and Legitimate Interests:
Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures; business processes and business management procedures.

·        Retention and Deletion:
Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.

·        Legal Bases:
Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); legal obligation (Art. 6(1) sentence 1 lit. c GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Further Information on Processing Activities, Procedures and Services

·        Event Management:
We process the data of participants in the events, functions and similar activities offered or organised by us (hereinafter uniformly referred to as “Participants” and “Events”) in order to enable them to participate in the Events and to make use of the services or actions associated with participation.

If, in this context, we process health-related data, religious, political or other special categories of data, this shall be carried out within the scope of manifest disclosure (e.g. in the case of thematically oriented events), for the purposes of health care or safety, or with the consent of the data subjects.

The required information is marked as such within the scope of the order, booking or comparable contractual conclusion and includes the information necessary for the provision of services and invoicing as well as contact information in order to be able to conduct any necessary consultations. Insofar as we obtain access to information of end customers, employees or other persons, we process such information in accordance with the statutory and contractual provisions; legal basis: performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

 

Payment Procedures

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

The data processed by the Payment Service Providers includes master data, such as name and address, banking data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract-related, transaction amount-related and recipient-related information. This information is required in order to carry out the transactions. However, the entered data is processed and stored solely by the Payment Service Providers. This means that we do not receive any account- or credit card-related information, but only information with confirmation or rejection of the payment. Under certain circumstances, the data may be transmitted by the Payment Service Providers to credit agencies. This transmission serves the purpose of identity and creditworthiness verification. In this respect, we refer to the terms and conditions and the privacy notices of the Payment Service Providers.

Payment transactions are subject to the terms and conditions and the privacy notices of the respective Payment Service Providers, which can be accessed within the respective websites or transaction applications. We also refer to these for the purposes of further information and the assertion of withdrawal, access and other data subject rights.

·        Categories of Data Processed:

Master data (e.g. full name, residential address, contact details, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contractual data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types used and operating systems, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, involved persons).

·        Data Subjects:
Service recipients and principals; business and contractual partners; prospective customers.

·        Purposes of Processing and Legitimate Interests:
Provision of contractual services and fulfilment of contractual obligations; business processes and business management procedures.

·        Retention and Deletion:
Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion”.

·        Legal Bases:
Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Further Information on Processing Activities, Procedures and Services:

·        PayPal: Payment services (technical integration of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg; legal basis: performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

Provision of the Online Offering and Web Hosting

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

·        Categories of Data Processed:
Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types used and operating systems, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, involved persons); log data (e.g. log files relating to logins or the retrieval of data or access times).

·        Data Subjects:
Users (e.g. website visitors, users of online services).

·        Purposes of Processing and Legitimate Interests:
Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures; reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); server monitoring and error detection.

·        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) sentence 1 lit. 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 basis: legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

·        Collection of Access Data and Log Files:
Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, volumes of data transmitted, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, for example to prevent overloading of the servers (particularly in the event of abusive attacks, so-called DDoS attacks), and also to ensure the utilisation and stability of the servers; legal basis: legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is excluded from deletion until final clarification of the respective incident.

·        Squarespace: Squarespace provides Software as a Service for the creation and hosting of websites; service provider: Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland; legal basis: legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy; data processing agreement: https://www.squarespace.com/dpa; basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.squarespace.com/dpa).

Use of Cookies

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

·        Notes on Data Protection Legal Bases:
Whether we process personal data using cookies depends on consent. Where consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

·        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 end device (e.g. browser or mobile application).

·        Permanent Cookies:
Permanent cookies remain stored even after the end device has been closed. For example, the login status can be stored and preferred content displayed directly when the user revisits a website. Likewise, the usage data collected with the aid of cookies may be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. within the scope of obtaining consent), they should assume that these are permanent and that the storage duration may be up to two years.

General Notes on Withdrawal and Objection (Opt-Out):
Users may withdraw the consent they have given at any time and may also object to the processing in accordance with statutory provisions, including by means of the privacy settings of their browser.

·        Categories of Data Processed:
Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, involved persons).

·        Data Subjects:
Users (e.g. website visitors, users of online services).

·        Legal Bases:
Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); consent (Art. 6(1) sentence 1 lit. a GDPR).

Further Information on Processing Activities, Procedures and Services:

·        Processing of Cookie Data on the Basis of Consent:
We use a consent management solution in which users’ consent to the use of cookies or to the procedures and providers specified within the consent management solution is obtained. This procedure serves to obtain, log, manage and withdraw consent, in particular with regard to the use of cookies and comparable technologies used for storing, reading and processing information on users’ end devices. Within the scope of this procedure, users’ consent for the use of cookies and the associated processing of information, including the specific processing operations and providers specified in the consent management procedure, is obtained. Users also have the option of managing and withdrawing their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with statutory 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. Insofar as no specific information is available regarding the providers of consent management services, the following general information shall apply: The storage period of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) as well as information on the browser, system and end device used; legal basis: consent (Art. 6(1) sentence 1 lit. a GDPR).

Contact and Enquiry Management

When contacting us (e.g. by post, contact form, e-mail, telephone or via social media), as well as within the scope of existing user and business relationships, the details of the enquiring persons are processed to the extent necessary in order to respond to the contact enquiries and any requested measures.

·        Categories of Data Processed:
Contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or visual messages and contributions and the information relating to them, such as information on authorship or time of creation); meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, involved persons).

·        Data Subjects:
Communication partners.

·        Purposes of Processing and Legitimate Interests:
Communication; organisational and administrative procedures; feedback (e.g. collection of feedback via online form); 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) sentence 1 lit. f GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

Further Information on Processing Activities, Procedures and Services:

·        Contact Form:
When contacting us via our contact form, by e-mail or other means of communication, we process the personal data transmitted to us in order to respond to and process the respective request. This generally includes details such as name, contact information and, where applicable, further information communicated to us which is required for appropriate processing. We use this data exclusively for the stated purpose of making contact and communication; legal bases: performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR), legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Surveys and Questionnaires
We conduct surveys and questionnaires in order to collect information for the respective communicated purpose of the survey or questionnaire. The surveys and questionnaires conducted by us (hereinafter referred to as “questionnaires”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the resumption of the survey by means of a cookie).

·        Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or visual messages and contributions and the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).

·        Data subjects: Participants.

·        Purposes of processing and legitimate interests: Feedback (e.g. collection of feedback via online form). Surveys and questionnaires (e.g. surveys with input options, multiple-choice questions).

·       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 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

·        Google Forms: Creation and evaluation of online forms, surveys, feedback forms, etc.; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.google.de/intl/de/forms; privacy policy: https://policies.google.com/privacy; data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause).

·        LimeSurvey: Implementation of online surveys; service provider: LimeSurvey GmbH Umfragedienste & Beratung, Papenreye 63, 22453 Hamburg, Germany; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.limesurvey.org/de. Privacy policy: https://www.limesurvey.org/de/datenschutzhinweise.

Web Analysis, Monitoring and Optimisation
Web analysis (also referred to as “reach measurement”) serves to evaluate the 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 aid of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used, or invite users to reuse them. It also enables us to identify which areas require optimisation.

In addition to web analysis, we may also use test procedures in order to test and optimise 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 in an end device and subsequently read. The information collected includes, in particular, visited websites and the elements used there, as well as technical information, such as the browser used, the computer system used and information on usage times. If users have 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, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) for the protection of users. In general, no clear user data (such as e-mail addresses or names) are stored within the framework of web analysis, A/B testing and optimisation, but rather pseudonyms. This means that neither we nor the providers of the software used 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: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

·        Types of data processed: Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).

·        Data subjects: Users (e.g. website visitors, users of online services).

·        Purposes of processing and legitimate interests: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.

·        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 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).


Further information on processing operations, 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 e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, accessed again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users referring to our online offering and technical aspects of their end devices and browsers.
Pseudonymous user profiles 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). In the case of EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being deleted immediately. 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 carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. 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: 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 the data processed).

Presences in Social Networks (Social Media)
We maintain online presences within social networks and, in this context, process user data in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users, as, for example, the enforcement of users’ rights could be made more difficult.

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

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

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

·        Types of data processed: Contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. textual or visual messages and contributions and the information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).

·        Data subjects: Users (e.g. website visitors, users of online services).

·        Purposes of processing and legitimate interests: Communication; feedback (e.g. collection of feedback via online form). Public relations work.

·        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 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

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

·        LinkedIn: Social network – together with LinkedIn Ireland Unlimited Company, we are jointly responsible for the collection (but not the further processing) of data from visitors used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles such as job function, country, industry, hierarchical 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 specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, submit requests for information or deletion directly to LinkedIn). Users’ rights (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; basis for third country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plug-ins and Embedded Functions and Content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “content”).

Integration always requires that the third-party providers of this content process the users’ IP address, as they would otherwise not be able to send the content to their browser without the IP address. The IP address is therefore required for the display of this content or functions. We endeavour to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” may be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, but may also be linked with such information from other sources.

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

·        Types of data processed: Usage data (e.g. page views and duration of visits, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).

·        Data subjects: Users (e.g. website visitors, users of online services).

·        Purposes of processing and legitimate interests: 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”. 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).

·        Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Amendment and Updating
We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing 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 any other individual notification.

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

Supervisory authority responsible for us:
Gegevensbeschermingsautoriteit / Autorité de protection des données
Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels/Bruxelles
https://www.gegevensbeschermingsautoriteit.be

Definitions of Terms
In this section you will find an overview of the terminology used in this privacy policy. Insofar as the terminology is defined by law, their legal definitions shall apply. The following explanations, on the other hand, are primarily intended to aid understanding.

·        Master data: Master data includes essential information necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include, inter alia, personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, facilities or systems by enabling unique assignment and communication.

·        Content data: Content data includes information generated in the course of the creation, editing and publication of content of any kind. 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, inter alia, telephone numbers, postal addresses and e-mail 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. As a rule, a cookie is stored on users’ devices within the websites on which the marketing measures take place and is then retrieved again on the target website. For example, this enables us to determine whether the advertisements we have 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 describing the context, origin and structure of other data. It may include information on file size, date of creation, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes processes and procedures within systems or organisations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing processes.

·        Usage data: Usage data refers to information that records how users interact with digital products, services or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they remain on certain pages and which paths they take through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, 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 referred to as the “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

·        Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data consisting of the use of 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 different information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, clicking behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.

·        Log data: Log data is information about events or activities recorded in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or to create performance reports.

·        Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the 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 reach analysis, operators of online offerings can, for example, recognise at what time users visit their websites and which content they are interested in. This allows them, for example, to better adapt the content of websites to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for reach analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.

·        Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online offering and use the processed data to technically optimise our online offering. Performance, utilisation and comparable technical values are processed which provide information on the stability and any anomalies of our online offering. In the event of errors and anomalies, individual requests of users of our online offering are recorded in order to identify and remedy sources of problems.

·        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 covers practically any handling of data, be it collection, evaluation, storage, transmission or deletion.

·        Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the administration and fulfilment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are decisive for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.

·        Payment data: Payment data includes all information required for the processing of payment transactions between buyers and sellers. This data is of decisive importance for electronic commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also include information about payment status, chargebacks, authorisations and fees.

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