Datenschutzerklaerung
1. Privacy Policy
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Information about the collection of personal data and contact details of the data controller
1.1 We are delighted that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. Personal data means any data with which you can be personally identified.
1.2 The data controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Sandra Sauter, Bergstraße 1 in 65558 Hirschberg, Germany, Tel.: +49 179-9307890, Email: sandra@holistic-touch.de. The data controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the data controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser's address bar.
2. Data collection when visiting our website
When you visit our website for informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to our server (so-called "server log files"). When you access our website, we collect the following data that is technically necessary for us to display the website to you:
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The website visited
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Date and time of access
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Amount of data sent in bytes
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Source/reference from which you accessed the page
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Browser used
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Operating system used
3) Cookies
To make your website visit attractive and enable the use of certain functions, we use cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e., after you close your browser (so-called session cookies). Other cookies remain on your device and enable us to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information to an individual extent, such as browser and location data, as well as IP address values.
Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can find the duration of each cookie storage in the overview of your web browser's cookie settings.
Some cookies are used to simplify the order process by storing settings (e.g., remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of a contract, according to Art. 6 para. 1 lit. a GDPR in case of consent given, or according to Art. 6 para. 1 lit. f GDPR for our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the site visit.
Please note that you can configure your browser settings according to your preferences, such as being informed about the setting of cookies, deciding on acceptance on a case-by-case basis, or rejecting cookies in certain cases or altogether. Each browser differs in how it manages cookie settings. This is described in the help menu of each browser, which explains how to change your cookie settings. You can find this information for the respective browsers at the following links:
Please note that if you do not accept cookies, the functionality of our website may be limited.
4) Contact
When contacting us (e.g., via contact form or email), personal data is collected. The specific data collected in the case of a contact form can be seen from the respective contact form fields. This data is used exclusively for the purpose of responding to your inquiry or for contacting you and the associated technical administration. The legal basis for processing this data is our legitimate interest in responding to your request pursuant to Art. 6(1)(f) GDPR. If your contact is aimed at concluding a contract, an additional legal basis for processing is Art. 6(1)(b) GDPR. Your data will be deleted after final processing of your request. This is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided there are no legal obligations to retain data.
5) Processing of Data upon Opening a Customer Account and for Contract Execution
Processing of Data upon Opening a Customer Account and for Contract Execution According to Art. 6(1)(b) GDPR, personal data will continue to be collected and processed if you provide it to us for the purpose of executing a contract or opening a customer account. The specific data collected can be seen from the respective input forms. Deleting your customer account is possible at any time and can be done by sending a message to the above-mentioned address of the responsible party. We store and use the data provided by you for contract execution. After complete execution of the contract or deletion of your customer account, your data will be blocked considering tax and commercial retention periods and deleted after these periods expire, unless you have expressly consented to further use of your data or we reserve the right to further data usage permitted by law.
6) Usage of Customer Data for Direct Advertising Newsletter Creation with Brevo
For sending our newsletters, we use the services of Brevo (short for Example-Revolution GmbH, Address, Country). Brevo is a service that assists us in managing and sending newsletters. The personal data of our newsletter subscribers is stored on Brevo's servers.
Which data is collected?
When you subscribe to our newsletter, the following data is collected:
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Your email address,
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Optional: Your name and additional voluntary information.
Purpose of data collection
The collection of your data is done to regularly send you information about our offers, news, and relevant topics via email.
Legal basis
The processing of your data is based on your consent according to Art. 6(1)(a) GDPR.
Data transmission and data protection
Your data is transmitted encrypted to Brevo and stored on secure servers. Brevo does not pass on your data to third parties and does not use it for its own purposes.
Withdrawal of your consent
You can withdraw your consent to the storage of your data and its use for sending newsletters at any time. You will find an unsubscribe link at the end of each newsletter, or you can contact us directly.
7) Data Processing for Order Fulfillment
7.1 To process your order, we collaborate with the following service providers who support us wholly or partially in executing concluded contracts. According to the following information, certain personal data will be transmitted to these service providers.
The personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, to the extent necessary for the delivery of the goods. We will forward your payment details to the commissioned credit institution as part of the payment processing, if this is necessary for the payment processing. If payment service providers are used, we will inform you about this explicitly below. The legal basis for the transfer of data is Art. 6(1)(b) GDPR.
8) Usage of Social Media: Social Plugins
8.1 Facebook as Standard Plugin
We use social plugins ("Plugins") from the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook") on our website.
You can usually recognize the plugins by the Facebook logo, which is a white "f" on a blue background. Other designs of the Facebook plugin can be viewed here: https://developers.facebook.com/docs/plugins
When you visit one of our web pages that contains such a plugin, your browser establishes a direct connection to Facebook's servers and transmits the content of the plugin directly to your browser, even if you do not have a Facebook profile or are not currently logged into Facebook. This information (including your IP address) is transmitted directly from your browser to a server of Facebook in the USA and stored there.
If you are logged into Facebook at the time, Facebook can directly associate your visit to our website with your Facebook profile. If you interact with a plugin (for example, by clicking the "Like" button or leaving a comment), this information is also transmitted directly to a server of Facebook and stored there. The actions may be published on your Facebook profile and shown to your Facebook friends.
Our legitimate interest lies in displaying personalized advertising and maximizing the full financial potential of our website. The legal basis is Art. 6(1)(f) GDPR.
Facebook's legitimate interest lies in displaying personalized advertising and in the demand-oriented design of its service. The legal basis is Art. 6(1)(f) GDPR.
If you do not wish for Facebook to associate the data collected via our website with your Facebook profile, you must log out of Facebook before visiting our website. You can also prevent the loading of Facebook plugins with add-ons for your browser, such as the script blocker "NoScript" (http://noscript.net/).
For more information, please refer to Facebook's privacy policy: http://www.facebook.com/policy.php
8.2 Instagram as Standard Plugin
We use social plugins ("Plugins") from the social network Instagram, operated by Instagram LLC., 1601 Willow Rd, Menlo Park, CA 94025, USA ("Instagram"), on our website.
You can usually recognize the plugins by the "Instagram camera" icon. Other designs of the Instagram plugin can be viewed here: http://blog.instagram.com/post/36222022872/introducing-instagram-badges.
When you visit one of our web pages that contains such a plugin, your browser establishes a direct connection to Instagram's servers and transmits the content of the plugin directly to your browser, even if you do not have an Instagram profile or are not currently logged into Instagram. This information (including your IP address) is transmitted directly from your browser to a server of Instagram in the USA and stored there.
If you are logged into Instagram at the time, Instagram can directly associate your visit to our website with your Instagram profile. If you interact with a plugin (for example, by clicking the "Instagram" button or leaving a comment), this information is also transmitted directly to a server of Instagram and stored there. The actions may be published on your Instagram profile and shown to your Instagram friends.
Our legitimate interest lies in displaying personalized advertising and maximizing the full financial potential of our website. The legal basis is Art. 6(1)(f) GDPR.
Instagram's legitimate interest lies in displaying personalized advertising and in the demand-oriented design of its service. The legal basis is Art. 6(1)(f) GDPR.
If you do not wish for Instagram to associate the data collected via our website with your Instagram profile, you must log out of Instagram before visiting our website. You can also prevent the loading of Instagram plugins with add-ons for your browser, such as the script blocker "NoScript" (http://noscript.net/).
For more information, please refer to Instagram's privacy policy: https://help.instagram.com/155833707900388/
9. Use of Social Media: Videos
Use of YouTube Videos
This website uses the YouTube embedding feature for displaying and playing videos from the provider "YouTube", which is operated by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").
The extended data protection mode is used here, which according to the provider only triggers storage of user information once the video(s) are played. When embedded YouTube videos are played, the provider "YouTube" uses cookies to collect information about user behavior. According to "YouTube", these are used, among other things, to record video statistics, improve user-friendliness, and prevent abusive actions. If you are logged into Google, your data will be directly associated with your account when you click on a video. If you do not wish this association with your YouTube profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation is carried out in particular in accordance with Art. 6(1)(f) GDPR based on Google's legitimate interests in displaying personalized advertising, conducting market research, and/or designing its website to meet users' needs. You have the right to object to the creation of these user profiles, and you must contact YouTube to exercise this right. When using YouTube, personal data may also be transferred to the servers of Google LLC in the USA.
Regardless of whether you play the embedded videos, accessing this website establishes a connection to the Google network, which may trigger further data processing operations beyond our control.
For more information on data protection at "YouTube", please refer to the provider's privacy policy: https://www.google.de/intl/de/policies/privacy
Where legally required, we have obtained your consent in accordance with Art. 6(1)(a) GDPR for the processing of your data as described above. You can revoke your consent at any time with effect for the future. To exercise your revocation, deactivate this service in the "Cookie Consent Tool" provided on the website.
10) Google AdSense
This website uses Google AdSense, a web advertising service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google AdSense uses cookies, which are text files stored on your computer that enable an analysis of your use of the website. In addition, Google AdSense also uses web beacons (small invisible graphics) to collect and evaluate simple actions such as visitor traffic on the website. The information generated by the cookie and/or web beacon about your use of this website (including your IP address) is usually transmitted to a Google server and stored there. This may also involve transmission to Google LLC servers in the United States.
Google uses the information obtained to analyze your usage behavior with regard to AdSense ads. The IP address transmitted by your browser as part of Google AdSense is not merged with other Google data. The information collected by Google may be transferred to third parties if required by law and/or if third parties process this data on behalf of Google.
The processing of data described above is carried out in accordance with Art. 6(1)(f) GDPR for the purpose of targeted advertising by third-party advertisers, whose ads are displayed based on evaluated user behavior on this website. This processing also serves our financial interest in maximizing the economic potential of our website through paid display of personalized third-party advertising content.
For more information about Google's privacy practices, please visit: https://www.google.de/policies/privacy/
You can permanently disable cookies for ad preferences by adjusting your browser settings accordingly or by downloading and installing the browser plug-in available at the following link: https://www.google.com/settings/ads/plugin?hl=de
Please note that certain features of this website may not function properly or at all if you have disabled the use of cookies.
Where legally required, we have obtained your consent in accordance with Art. 6(1)(a) GDPR for the processing of your data as described above. You can revoke your consent at any time with effect for the future. To exercise your revocation, please follow the above-mentioned procedure for objecting.
10.2 Facebook Custom Audiences and Facebook Marketing Services
Scope of Data Processing
Within our online offering, we use the so-called "Facebook Pixel" of the social network Facebook, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law. With the help of the Facebook Pixel, Facebook can determine the visitors of our online offering as a target group for the display of advertisements (so-called "Facebook Ads"). The Facebook Pixel is integrated directly by Facebook when our web pages are called up and can store a cookie on your device. If you subsequently log in to Facebook or are already logged in to Facebook, your visit to our online offering will be noted in your profile. The data collected about you is anonymous to us, so it does not provide us with any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and can be used by Facebook for its own market research and advertising purposes. If we should transmit data to Facebook for matching purposes, this data is locally encrypted on the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of comparing it with the equally encrypted data sets by Facebook. The processing of data by Facebook is carried out within the framework of Facebook's data usage policy. Accordingly, general notes on the presentation of Facebook ads, in the Data Usage Policy of Facebook. Specific information and details about the Facebook Pixel and its functionality are available in the Facebook Help section.
Legal Basis for Data Processing
Based on our legitimate interests in analyzing, optimizing, and economically operating our online offering and for these purposes.
Purpose of Data Processing
We use the Facebook Pixel to display Facebook Ads only to those Facebook users who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interests in specific topics or products determined by the websites visited), which we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of Facebook advertising for statistical and market research purposes, by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
Storage Duration
According to its own information, Facebook stores the date and time of your visit for a period of 90 days, the specific Internet address of the Social Plugin located on our Website, and other technical data such as the IP address, browser type, and operating system, in order to further optimize the services of Facebook. After 90 days, the data is anonymized so that it can no longer be associated with you.
Revocation and Deletion Options
You can object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To set what types of ads are shown to you within Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings. The settings are platform-independent, i.e., they are applied across all devices, such as desktop computers or mobile devices. You can also object to the use of cookies for range measurement and advertising purposes via the deactivation page of the Network Advertising Initiative and additionally the US American website or the European website.
10.3 Use of Affiliate Programs
Amazon Partner Program (AmazonPartnerNet)
We participate in the Amazon EU S.a.r.l. Partner Program "AmazonPartnerNet" at 38 avenue John F. Kennedy, L-1855 Luxembourg (hereinafter "Amazon"). In this context, we have placed advertisements on our website as links that lead to offers on various Amazon websites. Amazon uses cookies. These are small text files that are stored on your end device in order to trace the origin of orders generated through such links. Amazon can recognize, among other things, that you clicked on the partner link on our website. This information is needed for payment processing between us and Amazon. If the information also contains personal data, the described processing is based on our legitimate financial interest in processing commission payments with Amazon in accordance with Art. 6(1)(f) GDPR.
Further information on data use by Amazon can be found in the Amazon.de privacy policy at https://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401. If you want to block the evaluation of user behavior via cookies, you can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. You can also disable interest-based ads on Amazon via the link https://www.amazon.de/gp/dra/info.
Where legally required, we have obtained your consent in accordance with Art. 6(1)(a) GDPR for the processing of your data as described above. You can revoke your consent at any time with effect for the future. To exercise your revocation, please follow the above-mentioned procedure for objecting.
11) Wordfence
For security purposes, this website uses the plugin "Wordfence," a service provided by Defiant Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter "Wordfence"). The plugin protects the website and its associated IT infrastructure against unauthorized third-party access, cyber-attacks, viruses, and malware. Wordfence collects users' IP addresses and potentially other data regarding your behavior on our website (especially accessed URLs and header information) to detect and mitigate illegitimate page access and threats. The captured IP address is compared with a list of known attackers. If the captured IP address is identified as a security risk, Wordfence can automatically block access to the page. The information collected is transmitted to a Defiant Inc. server in the USA and stored there. These described data processing activities are carried out in accordance with Art. 6(1)(f) GDPR based on our legitimate interests in protecting the website against harmful cyber-attacks and ensuring structural and data integrity and security. Defiant Inc. relies on the standard contractual clauses pursuant to Art. 46(2)(c) GDPR as the legal basis for data transfers to the USA. If website visitors have login rights, Wordfence also sets cookies (= small text files) on the visitor's respective end device. These cookies can read certain location and device information to assess whether the login-authorized access originates from an authorized person. At the same time, access rights can be evaluated via the cookies and released through an internal firewall according to the permission level. Finally, these cookies serve to register irregular accesses by page administrators from new devices or new locations and notify other administrators accordingly. These cookies are only set if a user has login rights. Wordfence does not set cookies for visitors without login authorization. If personal data are processed via the cookies, the processing is carried out in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in preventing illegitimate access to page management and defending against unauthorized administrator accesses. We have concluded a data processing agreement with Defiant Inc. ("Data Processing Agreement") whereby we obligate the company to protect the data of website visitors and not to disclose it to third parties. For further information on Defiant Inc.'s data use for Wordfence, please refer to the Wordfence privacy policy at https://www.wordfence.com/privacy-policy/.
11.2 - Zoom We use the service "Zoom" from Zoom Video Communications Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA (hereinafter "Zoom") to conduct online meetings, video conferences, and/or webinars. When using Zoom, different data are processed. The extent of data processed depends on the data you provide before or during participation in an online meeting, video conference, or webinar. In the context of using Zoom, communication participant data is processed and stored on Zoom servers. This data may include your registration data (name, email address, optional phone number, and password) and meeting data (topic, participant IP address, device information, optional description). In addition, visual and auditory contributions of participants, as well as voice inputs in chats, can be processed. For the processing of personal data necessary for the performance of a contract with you (this also applies to processing operations required for the implementation of pre-contractual measures), Art. 6(1)(b) GDPR serves as the legal basis. If you have given us consent to process your data, the processing is based on Art. 6(1)(a) GDPR. A granted consent can be revoked at any time with effect for the future. Furthermore, the legal basis for data processing in the conduct of online meetings, video conferences, or webinars is our legitimate interest pursuant to Art. 6(1)(f) GDPR in the effective conduct of the online meeting, webinar, or video conference. For more information on data use by Zoom, please refer to Zoom's privacy policy at https://zoom.us/docs/de-de/privacy-and-legal.html
12) Rights of the Data Subject 12.1 Current data protection law grants you comprehensive rights as a data subject (rights to information and intervention), about which we inform you below: Right to information pursuant to Art. 15 GDPR: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and other specified information. Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you. Right to erasure ("right to be forgotten") pursuant to Art. 17 GDPR: You have the right to obtain the erasure of personal data concerning you without undue delay under certain conditions. Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to obtain restriction of processing where one of the specified conditions applies. Right to data portability pursuant to Art. 20 GDPR: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format or to transmit those data to another controller. Right to withdraw consent pursuant to Art. 7(3) GDPR: You have the right to withdraw your consent to the processing of your personal data at any time with future effect. Right to lodge a complaint pursuant to Art. 77 GDPR: 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.
12.2 Right to Object IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST IN THE CONTEXT OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO SUCH PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE. IF YOU MAKE USE OF YOUR RIGHT TO OBJECT, WE WILL CEASE THE PROCESSING OF THE AFFECTED DATA. HOWEVER, FURTHER PROCESSING REMAINS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS. IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSES OF SUCH MARKETING. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
13) Duration of storage of personal data
The duration of storage of personal data is determined based on the respective legal basis, the purpose of processing, and, where applicable, the relevant statutory retention periods (e.g., commercial and tax retention periods).
When processing personal data based on explicit consent pursuant to Art. 6(1)(a) GDPR, this data is stored until the data subject withdraws their consent.
If there are statutory retention periods for data processed on the basis of contractual or similar legal obligations under Art. 6(1)(b) GDPR, this data is routinely deleted after the retention periods expire, provided it is no longer necessary for contract fulfillment or initiation, and/or there is no legitimate interest on our part to continue storing it.
Personal data processed based on Art. 6(1)(f) GDPR is stored until the data subject exercises their right to object under Art. 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims.
Personal data processed for direct marketing purposes under Art. 6(1)(f) GDPR is stored until the data subject exercises their right to object under Art. 21(2) GDPR.
Unless otherwise specified in other sections of this statement regarding specific processing situations, stored personal data is deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.
14. Administration, financial accounting, office organization, contact management
We process data as part of administrative tasks and the organization of our business, financial accounting, and compliance with legal obligations such as archiving. Here, we process the same data that we use in the provision of our contractual services. The legal bases for processing are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. This processing concerns customers, prospects, business partners, and website visitors. The purpose and our interest in processing lie in the administration, financial accounting, office organization, and archiving of data, which are tasks necessary for maintaining our business activities, fulfilling our tasks, and providing our services. The deletion of data concerning contractual services and contractual communication corresponds to the details provided for these processing activities.
In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we generally store information about suppliers, organizers, and other business partners for the purpose of future contact. These predominantly company-related data are stored permanently.
15) Business analysis and market research
In order to operate our business economically and to identify market trends and the desires of contractual partners and users, we analyze the data available to us regarding business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata based on Art. 6(1)(f) GDPR. The affected individuals include contractual partners, prospects, customers, visitors, and users of our online offerings.
These analyses are conducted for the purpose of business evaluations, marketing, and market research. In doing so, we may consider profiles of registered users, including information about the services they have used. The analyses are aimed at enhancing user friendliness, optimizing our offerings, and improving business efficiency. The analyses are for our own use only and are not disclosed externally unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personally identifiable, they will be deleted or anonymized upon termination by the user, otherwise within two years after the conclusion of the contract. Additionally, comprehensive business analyses and general trend determinations are preferably created anonymously whenever possible.