Privacy Policy

This Privacy Policy is provided in English. The legal basis remains German law (GDPR, TMG, MStV).

Privacy Policy

Preamble

The following privacy policy is intended to inform you about the types of personal data (hereinafter also referred to as ‘data’) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data 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.

Status: 29 September 2025

Table of contents

  • Preamble
  • Controller
  • Overview of processing
  • Relevant legal basis
  • Security measures
  • 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
  • Web analysis, monitoring and optimisation
  • Presence on social networks (social media)
  • Changes and updates

Responsible party

Mareike Kempf

Arnoldstraße 32

22765 Hamburg

Germany

Email address: mari__kempf@gmx.de

Legal notice: https://marikempf.com/295-2/

The following overview summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

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

Categories of data subjects

  • Communication partners.
  • Users.

Purposes of processing

  • Communication.
  • Security measures.
  • Reach measurement.
  • Organisational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.

 

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under 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 registered office. If more specific legal bases are relevant in individual cases, we will inform you of this 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.
  • 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.

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

Note on the applicability of the GDPR and Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms ‘processing’ of ‘personal data’, ‘overriding interest’ and ‘sensitive personal data’ used in the Swiss FADP, the terms “processing” of ‘personal data’, ‘legitimate interest’ and ‘special categories of data’ used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of the Swiss DSG.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation relating to it. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorised access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data 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 encrypted.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons agencies or companies (which can be identified by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data 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 secure 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 that comply with the requirements of the EU Commission and stipulate contractual obligations for the protection of your data.

This dual safeguard ensures comprehensive protection for your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers 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 US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the 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 legal requirements as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage 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 to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing procedures.

  • If there are several specifications regarding the retention period or deletion deadlines for a date, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
  • Storage and deletion of data: The following general periods apply to storage and archiving under German law:
  • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).
  • 8 years – accounting documents, such as invoices and expense receipts (Section 147(1) Nos. 4 and 4a in conjunction with Section 147(3) sentence 1 of the German Fiscal Code (AO) and Section 257(1) No. 4 in conjunction with Section 257(4) of the German Commercial Code (HGB)).
  • 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g. hourly wage slips, operating accounts, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting documents, and cash register receipts (Section 147 (1) No. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) No. 2 and 3 in conjunction with (4) HGB).
  • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of data subjects

  • Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
  • Right to object: You have the right 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 Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request that data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • 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 legal requirements, or to request that it be transferred to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Provision of online services and web hosting

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

  • Types of data processed: usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing operations, procedures and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a ‘web host’). Legal basis: 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 websites and files accessed, the date and time of access, the amount of data 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 can be used for security purposes, e.g. to prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilisation and stability; legal basis: legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that needs to be kept for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

Use of cookies

The term ‘cookies’ refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security and convenience of online services and to analyse visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If 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 known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. This allows, for example, the log-in status to be stored and preferred content to be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. 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 period can be up to two years.

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

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

Web analysis, monitoring and optimisation

Web analysis (also known as ‘reach measurement’) is used to evaluate visitor traffic to 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 reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently, or invite reuse. It also enables us to identify areas that require optimisation.

In addition to web analysis, we can also use test procedures to test and optimise different versions of our online offering or its components.

Unless otherwise specified 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 on a terminal device and then read out. The information collected includes, in particular, websites visited and 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 agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context 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 purpose 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, economical 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, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: 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.
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (unless otherwise specified, 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 basis: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods 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 is used to assign analysis information to a terminal device in order to identify which content users have accessed within one or more usage processes, which search terms they have used, which they have accessed again or with which they have interacted with our online offering. The time and duration of use are also stored, as well as the sources of users who refer to our online offering and technical aspects of their terminal devices and browsers.

Pseudonymous user profiles are created using 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 counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. 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 basis: 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: Data Privacy Framework (DPF), 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).

Presence on social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may pose 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 can be created based on the usage behaviour and resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For this reason, cookies are usually stored on users’ computers, in which their usage behaviour and interests are stored. In addition, data can also be stored in the usage profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer you 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 most effectively asserted with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. However, if you still require assistance, please contact us.

Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, 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: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and subscribe to profiles and pages; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com; privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for collecting (but not further processing) data from visitors, which is used to create ‘Page Insights’ (statistics) for 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. Details about the devices used are also collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchy level, company size and employment status. Information on LinkedIn’s processing of user data can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.

We have entered into a special agreement with LinkedIn Ireland (‘Page Insights Joint Controller Addendum’, https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that 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). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer 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 transfer 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(1)(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), https://legal.linkedin.com/dpa. Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Changes and updates

We ask that you regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require action on your part (e.g. consent) or other individual notification.

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

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