Dirk Matthias Rudolf

Privacy policy

The German version of this page is authoritative.

Preamble

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement 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 services").

The terms used are not gender-specific.

Last Update: 1. November 2026

Table of contents

Controller

Dirk Matthias Rudolf
Torfstraße 10
13353 Berlin

E-mail address: kontakt@rudolf.io

Legal notice

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data.
  • Payment Data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Log data.

Categories of Data Subjects

  • Service recipients and clients.
  • Prospective customers.
  • Communication partner.
  • Users.
  • Business and contractual partners.
  • Third parties.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Office and organisational procedures.
  • Organisational and Administrative Procedures.
  • Feedback.
  • Marketing.
  • Provision of our online services and usability.
  • Information technology infrastructure.
  • Financial and Payment Management.
  • Public relations.
  • Sales promotion.
  • Business processes and management procedures.
  • Artificial Intelligence (AI).

Relevant legal bases

Relevant legal bases according to the GDPR: In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.

  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations apply to data protection in Germany. This includes in particular the Federal Data Protection Act (BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, data protection laws of the individual federal states may apply.

Security Precautions

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

The 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, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorized access, we employ 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 that is transferred between the website or app and the user's browser (or between two servers), thereby safeguarding the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to the highest security standards. When a website is secured with 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 securely and encryptedly transmitted.

Transmission of Personal Data

In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of 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 using third-party services or the disclosure or transfer of data to other individuals, entities, or companies (which becomes apparent either from the postal address of the respective provider or when explicitly mentioned in the privacy policy regarding data transfer to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by the EU Commission's adequacy decision of July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers, which comply with the EU Commission's requirements and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF serves as the primary level of protection, while the Standard Contractual Clauses act as an additional security measure. Should any changes occur within the DPF framework, the Standard Contractual Clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we will inform you whether they are certified under the DPF and if Standard Contractual Clauses are in place. The list of certified companies and further information about the DPF can be found on the U.S. Department of Commerce's website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, appropriate safeguards apply, particularly 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 EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

We will inform you which of our service providers are certified under the Data Privacy Framework as part of our data protection notices.

General Information on Data Retention and Deletion

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

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or 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 specifically applicable to certain processing processes.

In cases where multiple retention periods or deletion deadlines for a date are specified, the longest period always prevails.

Data that is no longer stored for its originally intended purpose but due to legal requirements or other reasons are processed exclusively for the reasons justifying their retention.

Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:

  • 10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 8 years - Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB))
  • 6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes Section (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).
  • 3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).

Start of the period at the end of the year: If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.

Rights of Data Subjects

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

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. In particular, you may lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work or the place of the alleged infringement.

Business services

We process personal data of our contractual and business partners, such as Customers, Clients, Prospective Customers, Suppliers and other cooperation partners (collectively referred to as "Contractual Partners"), for the initiation, execution and settlement of contractual relationships as well as comparable legal relationships. This also includes pre-contractual measures carried out at the request of the parties and communication related to the respective contractual relationship.

Processing serves in particular to fulfil our primary and secondary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty claims and other service disruptions, processing revocations, terminations of continuing obligations, reversals, refunds as well as handling other contract-related statements and enquiries. Both one-off contracts and ongoing contractual relationships are covered.

In particular, we process master data such as name, address and where applicable company name; contact details such as email address and telephone number; contract and service data such as subject matter of the contract, duration of the contract, order or transaction number; usage and performance data; payment and billing data; as well as communication content and histories. Where necessary, we also process data disclosed or transmitted to us in connection with carrying out an assignment.

Furthermore, we process the data to safeguard our rights and to comply with legal obligations. This particularly includes commercial law and tax law retention requirements, documentation obligations as well as possible duties of proof or accountability. Processing may also take place on the basis of our legitimate interests in proper business management, internal administration, risk control and IT security as well as in protecting our business operations and Contractual Partners against misuse or threats to data, secrets or other legal assets. This may include involving external Service Providers such as IT- and telecommunications providers, transport- or logistics companies, payment service providers, banks, tax advisors or legal advisors or other vicarious agents insofar as this is required for executing contracts or fulfilling legal obligations.

Personal data will only be passed on to third parties if this is necessary for fulfilling a contract or conducting pre-contractual measures; safeguarding legitimate interests; or complying with statutory obligations. We will inform you separately within this privacy policy about any further processing activities—particularly those undertaken for marketing purposes.

Which specific data is required in each case will be communicated to Contractual Partners during collection—for example by appropriate labelling in online forms or during personal contact.

Data will be deleted once it is no longer required for these purposes provided there are no statutory retention requirements preventing deletion. Statutory retention periods—particularly under commercial- or tax law—may require longer storage periods. Data transmitted in connection with a specific assignment will be deleted after completion of that assignment and expiration of any applicable retention period unless further statutory or contractual storage obligations exist.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract object, duration, 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 fulfillment of contractual obligations; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Project and Development Services: We process the data of our customers and clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as associated activities and to pay for and make available such services or works or to perform such services or works.

    The required information is indicated as such within the framework of the conclusion of the agreement, order or equivalent contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to the information of end customers, employees or other persons, we process it in accordance with the legal and contractual requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Business processes and operations

Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties - are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Log data (e.g. log files concerning logins or data retrieval or access times.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
  • Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Third parties. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). Compliance with a legal obligation (Article 6 (1) (c) GDPR).

Further information on processing methods, procedures and services used:

  • Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
  • Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Provision of online services and web hosting

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

  • Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)). Security measures.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, 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 hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically 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 abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
  • Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://docs.hetzner.com/general/company-and-policy/data-protection-at-hetzner. Data Processing Agreement: https://docs.hetzner.com/general/company-and-policy/data-protection-at-hetzner.

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of processing and legitimate interests: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system" as defined in Article 3 No. 1 of the AI Regulation, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

  • Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services). Third parties.
  • Purposes of processing and legitimate interests: Artificial Intelligence (AI).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • ChatGPT: AI-based service designed to understand and generate natural language and related input and data, analyze information, and make predictions ("AI", meaning "Artificial Intelligence" shall be construed in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://openai.com/chatgpt/overview/; Privacy Policy: https://openai.com/policies/privacy-policy/. Opt-Out: https://privacy.openai.com/policies?modal=select-subject.
  • Claude (Anthropic): AI-based services for creating and editing texts and software source code, which we use in the context of our business services. Personal data may be processed insofar as it is contained in the content we enter (e.g. correspondence, documents, source code). We only enter the content required for the respective purpose; according to the settings we have chosen, the input is not used to train the provider's models. Legal basis: 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). Data processing agreement: https://www.anthropic.com/legal/commercial-terms. Basis for third-country transfers: Standard contractual clauses; Service provider: Anthropic, PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Website: https://www.anthropic.com. Privacy Policy: https://www.anthropic.com/legal/privacy.

Cloud Services

We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a Service") provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case of media control).

  • Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners. Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Profiles in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the 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 entail risks for users, e.g. by making it more difficult to enforce users' rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data, which is used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. It also includes details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as profile details of users, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn 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 LinkedIn must comply with and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of users (particularly the right to information, deletion, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by our agreements with LinkedIn. The joint responsibility is limited to the collection of data and its transmission 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, particularly concerning the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 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), Standard Contractual Clauses (https://www.linkedin.com/legal/privacy-policy). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.xing.com. Privacy Policy: https://privacy.xing.com/en.

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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

Supervisory authority competent for us:

Berliner Beauftragte für Datenschutz und Informationsfreiheit (Berlin Commissioner for Data Protection and Freedom of Information)
Alt-Moabit 59-61
10555 Berlin, Germany

Terminology and Definitions

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

  • Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.
  • Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.
  • Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.
  • Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.
  • Controller: "Controller" means 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.
  • Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.
  • Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.
  • Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.
  • Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.
  • Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
  • Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings