Privacy Policy

We are delighted that you have shown interest in our enterprise. Data protection is of an exceptionally high priority for the management of the Thronos Design. The use of the Internet pages of the Thronos Design is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, Address, email address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR) and the country-specific data protection regulations applicable to the Thronos Design. Utilizing this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, Thronos Design has implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through this website. However, Internet-based data transmissions may have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject can transfer personal data to us via alternative means, e.g., by telephone.

  1. Definitions

The data protection declaration of the Thronos Design is based on the terms used by the European legislator for adopting the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, customers, and business partners. To ensure this, we would like first to explain the terminology used.

In this data protection declaration, we use, among other things, the following terms:

  1. Personal data
  • Personal data is information about an identifiable natural person (“data subject”). An identifiable natural person 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.

  1. Data subject
  • The data subject is any identified or identifiable natural person whose personal data is processed by the responsible controller.

  1. Processing
  • Processing is any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  1. Restriction of processing
  • Restriction of processing is the marking of stored personal data to limit their processing in the future.

  1. Profiling
  • Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyze or predict characteristics concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

  1. Pseudonymization
  • Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

  1. Controller or controller responsible for the processing
  • The controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

  1. Processor
  • A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

  1. Recipient
  • The recipient is a natural or legal person, public authority, agency, or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.

  1. Third-party
  • The third party is a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

 

  1. Consent
  • Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by explicit affirmative action, signify Agreement to the processing of personal data relating to them.

 

  1. Name and Address of the – Data Protection Officer (DPO) hereinafter “The Controller”

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union, and other provisions related to data protection, is:

Thronos Design

Ioannou Pantazidou 50

54 352 Thessaloniki

Greece

Phone: 00306949385807

Email: info@thronosdesign.com

Website: www.thronosdesign.com



  1. Cookies

The Internet pages of the Thronos Design use cookies. Cookies are text files stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. The unique cookie ID can recognize and identify a particular Internet browser. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other web browsers containing other cookies.

Through the use of cookies, the Thronos Design can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. By means of a cookie, the information and offers on our website can be optimized with the user in mind. The website user that uses cookies, e.g., does not have to enter access data each time the website is accessed because the website takes this over, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles a customer places in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website utilizing a corresponding setting of the Internet browser used and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted anytime via an Internet browser or other software. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

 

  1. Collection of general data and information

The website of Thronos Design collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files collected may be:

  1. the browser types and versions used,
  2. the operating system used by the accessing system,
  3. the website from which an accessing system reaches our website (so-called referrers),
  4. the sub-websites,
  5. the date and time of access to the Internet site,
  6. an Internet protocol address (IP address),
  7. the Internet service provider of the accessing system, and
  8. any similar data and information may be used during attacks on our information technology systems.

When using these general data and information, the Thronos Design does not draw any conclusions about the data subject. Instead, this information is needed to:

  1. deliver the content of our website correctly,
  2. optimize the content of our website as well as its advertisement,
  3. ensure the long-term viability of our information technology systems and website technology, and
  4. provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Therefore, the Thronos Design analyzes anonymously collected data and information statistically, intending to increase our enterprise’s data protection and security and ensure optimal safety for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

 

  1. Registration on our website

The data subject can register on the controller’s website by indicating personal data. The respective input mask used for the registration determines which personal data are transmitted to the controller. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for his purposes. The controller may request transfer to one or more processors (e.g., a parcel service) that also use personal data for an internal purpose attributable to the controller.

Insofar as the storage of this data is essential to secure the controller. By registering on the controller’s website, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—the registration date and time are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. This data is not passed on to third parties unless there is a statutory obligation to pass on the data or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter. Registered persons are free to change the personal data specified during the registration or delete them entirely from the controller’s data stock.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject insofar as there are no statutory storage obligations. In this respect, the entire controller’s employees are available to the data subject as contact persons.

 

  1. Subscription to our newsletters

On Thronos Design’s website, users can subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted and when the controller orders the newsletter.

The Thronos Design informs its customers and business partners regularly by means of a newsletter about enterprise offers. The data subject may only receive the enterprise’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the email address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer or the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website or to communicate this to the controller differently.

 

  1. Newsletter-Tracking

The newsletter of the Thronos Design contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Thronos Design may see if and when a data subject opened an email and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the newsletter’s shipping and adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the separate declaration of consent issued through the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Thronos Design automatically regards a withdrawal from the receipt of the newsletter as a revocation.


  1. Contact possibility via the website

The website of the Thronos Design contains information that enables quick electronic contact with our enterprise and direct communication with us, including a general address of the so-called electronic mail (email address). Personal data transmitted voluntarily by a data subject to the controller are stored for processing or contacting the subject. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. There is no transfer of this personal data to third parties.


  1. Comments function in the blog on the website

The Thronos Design allows users to leave individual comments on individual blog contributions on a blog on the controller’s website. A blog is a web-based, publicly-accessible portal through which one or more people called bloggers or web bloggers may post articles or write down thoughts in so-called blogposts. Third parties may usually comment on blog posts.

If a data subject leaves a comment on the blog published on this website, the comments made by the subject are also stored and published, as well as information on the date of the commentary and the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons and in case the data subject violates the rights of third parties or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller so that he can exculpate in the event of an infringement. This collected personal data will only be passed to third parties if such a transfer is required by law or serves the aim of the defense of the data controller.

  1. Subscription to comments in the blog on the website

Third parties may subscribe to the comments made in the blog of the Thronos Design. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.

Suppose a data subject decides to subscribe to the option. In that case, the controller will send an automatic confirmation email to check the double opt-in procedure as to whether the owner of the specified email address decided in favor of this option. The option to subscribe to comments may be terminated at any time.

  1. Routine erasure and blocking of personal data

The data controller shall process and store the subject’s personal data only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Rights of the data subject

  1. Right of confirmation
  • Each data subject shall have the right granted by the European legislator to obtain confirmation from the controller as to whether personal data concerning them are being processed. If a data subject wishes to avail himself of this right of confirmation, they may contact any controller employee at any time.

  1. Right of access
  • Each data subject shall have the right granted by the European legislator to obtain free information about their personal data stored at any time and a copy of this information from the controller. Furthermore, the European directives and regulations grant the data subject access to the following information:
    • the purposes of the processing;
    • the categories of personal data concerned;
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
    • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
    • the existence of the right to complain with a supervisory authority;
    • where the personal data are not collected from the data subject, any available information as to their source;
    • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved and the significance and envisaged consequences of such processing for the data subject.
  • Furthermore, the data subject shall have a right to obtain information on whether personal data are transferred to a third country or an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
  • If a data subject wishes to avail himself of this right of access, they may contact any controller employee at any time.

  1. Right to rectification
  • Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • If a data subject wishes to exercise this right to rectification, they may contact any controller employee at any time.

  1. Right to erasure (Right to be forgotten)
  • Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller shall have an obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
    • Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
    • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
    • The data subject objects to the processing according to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing according to Article 21(2) of the GDPR.
    • The personal data have been unlawfully processed.
    • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
    • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
  • If one of the reasons mentioned above applies, and a data subject wishes to request the erasure of personal data stored by the Thronos Design, they may contact any controller employee at any time. An employee of Thronos Design shall promptly ensure that the erasure request is complied with immediately.
  • Where the controller has made personal data public and is obliged under Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Employees of the Thronos Design will arrange the necessary measures in individual cases.
  1. Right of restriction of processing
  • Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
    • The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
    • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
    • The controller no longer needs the personal data for the purposes of the processing, but the data subject for the establishment, exercise, or defense of legal claims requires them.
    • The data subject has objected to processing according to Article 21(1) of the GDPR pending the verification of whether the controller’s legitimate grounds override those of the data subject.
  • If one of the conditions mentioned above is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Thronos Design, they may at any time contact any employee of the controller. The employee of Thronos Design will arrange the restriction of the processing.
  1. Right to data portability
  • Each data subject shall have the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller in a structured, commonly used, and machine-readable format. They shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent according to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract according to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller.
  • Furthermore, in exercising their right to data portability under Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
  • In order to assert the right to data portability, the data subject may contact any employee of Thronos Design at any time.
  1. Right to object
  • Each data subject shall have the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to the processing of personal data concerning them, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
  • The Thronos Design shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims.
  • If Thronos Design processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning them for such marketing. This applies to profiling to the extent that it relates to such direct marketing. If the data subject objects to the Thronos Design for the processing for direct marketing purposes, the Thronos Design will no longer process the personal data for these purposes.
  • In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them by the Thronos Design for scientific or historical research purposes or statistical purposes under Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of Thronos Design. In addition, the data subject is free in using information society services, notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

  1. Automated individual decision-making, including profiling
  • Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them, or similarly significantly affects them, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
  • If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Thronos Design shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.
  • If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact any employee of the Thronos Design.
  1. Right, to withdraw data protection consent.
  • Each data subject shall have the right granted by the European legislator to withdraw their consent to processing their personal data at any time.
  • If the data subject wishes to exercise the right to withdraw the consent, they may, at any time, contact any employee of the Thronos Design.
  1. Data protection for applications and the application procedures

The data controller shall collect and process applicants’ personal data to process the application procedure. The processing may also be carried out electronically. This is the case, particularly if an applicant submits corresponding application documents by email or utilizing a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored to process the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Another legitimate interest in this relation is, e.g., a burden of proof in a procedure under the General Equal Treatment Act (AGG).

 

  1. Data Protection provisions about the application and use of AddThis

On this website, the data controller has integrated components of the enterprise AddThis. AddThis is a so-called bookmarking provider. The service allows for simplified bookmarking of Internet pages via buttons. A list of bookmarking and sharing services is displayed by clicking on the AddThis component with the mouse or by clicking on it. AddThis is used on over 15 million websites, and the buttons are displayed, according to the information of the operating enterprise, over 20 billion times a year.

The operating company of AddThis is Oracle Corporation, 10 Van de Graaff Drive, Burlington, MA 01803, USA.

By calling up one of the website’s pages, which is operated by the controller, and on which an AddThis component has been integrated, the Internet browser of the data subject is automatically prompted by the respective AddThis component to download data from the website www.addthis.com. Within the framework of this technical procedure, AddThis is informed of the visit and the specific individual page of this website used by the data subject with the help of information technology. In addition, AddThis is informed about the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject, the browser type and language, the web page accessed before our website, the date and the time of the visit to our website. AddThis uses this data to create anonymous user profiles. The data and information transmitted to AddThis will enable the enterprise AddThis, as well as affiliates or their partner-enterprises, to contact visitors of the controller’s web pages with personalized and interest-based advertising.

AddThis displays personalized and interest-based advertising based on a cookie set by the enterprise. This cookie analyzes the individual surfing behavior of the computer system used by the data subject. The cookie saves the computer-based outgoing visits to Internet pages.

The data subject may, at any time, prevent the setting of cookies through our website utilizing a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser would also prevent AddThis from setting a cookie on the information technology system of the data subject. AddThis may also delete cookies anytime via an Internet browser or other software.

The data subject can also object permanently to the processing of personal data by AddThis. For this purpose, the data subject must click the opt-out button under the link https://www.addthis.com/privacy/opt-out, which sets an opt-out cookie. The opt-out cookie used for this purpose is placed on the information technology system used by the data subject. If the data subject deletes the cookies from his system, the data subject must call the link again and set a new opt-out cookie.

However, with the setting of the opt-out cookie, the controller’s websites are no longer entirely usable by the data subject.

The applicable data protection provisions of AddThis may be accessed at https://www.addthis.com/privacy/privacy-policy.

 

  1. Data protection provisions about the application and use of Facebook

On this website, the controller has integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community that usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for exchanging opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside the United States or Canada, the controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook Plug-ins may be accessed at https://developers.facebook.com/docs/plugins/. During this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in simultaneously on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g., the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Through the Facebook component, Facebook always receives information about a visit to our website by the data subject whenever the data subject is logged in simultaneously on Facebook during the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component. If such a transmission of information to Facebook is not desirable for the data subject, they may prevent this by logging off from their Facebook account before a call-up to our website is made.

The data protection guideline published by Facebook, available at https://facebook.com/about/privacy/, provides information about Facebook’s collection, processing, and use of personal data. In addition, it is explained there what setting options Facebook offers to protect the data subject’s privacy. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. The data subject may use these applications to eliminate data transmission to Facebook.

 

  1. Data protection provisions about the application and use of Google Analytics (with anonymization function)

Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. Web analytics are mainly used for the optimization of a website and to carry out a cost-benefit analysis of Internet advertising. A web analysis service collects, among other things, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. On this website, the controller has integrated the component of Google Analytics (with the anonymizer function).

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

For web analytics through Google Analytics, the controller uses the application “_gat. _anonymizeIp”. Utilizing this application, the IP address of the data subject’s Internet connection is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for online advertising and the settlement of commissions to Google. During this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, among other things, to understand the origin of visitors and clicks and subsequently create commission settlements.

The cookie stores personal information, such as the access time, the location from which the access was made, and the data subject’s frequency of visits to our website. Google stores these personal data in the United States of America. With each visit to our Internet site, personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. Google may pass the personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time utilizing a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already used by Google Analytics may be deleted anytime via a web browser or other software programs.

In addition, the data subject can object to a collection of data generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics, through JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person attributable to their sphere of competence or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-on.

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and https://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.

 

  1. Data protection provisions about the application and use of Google Remarketing

On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google AdWords that allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s site. Therefore, integrating Google Remarketing enables an enterprise to create user-based advertising and thus show relevant advertisements to interested Internet users.

The operating company of the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or other websites, which are based on individual needs and matched to the interests of Internet users.

Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the cookie setting, Google enables a recognition of the visitor to our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which Google Remarketing has integrated the service, the data subject’s web browser identifies automatically with Google. During this technical procedure, Google receives personal information, such as the IP address or the surfing behavior of the user, which Google uses, among other things, for the insertion of interest-relevant advertising.

The cookie is used to store personal information, e.g., the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. Google stores these personal data in the United States of America. Google may pass the personal data collected through the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time utilizing a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted anytime via a web browser or other software programs.

In addition, the data subject can object to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser the data subject uses.

Further information and the actual data protection provisions of Google may be retrieved at https://www.google.com/intl/en/policies/privacy/.

 

  1. Data protection provisions about the application and use of Google-AdWords

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords, with the help of which an ad on Google’s search results is only displayed when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.

The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by including relevant advertising on the websites of third parties and in the search engine results of the search engine Google the insertion of third-party advertising on our website.

If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether specific sub-pages, e.g., the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.

Google uses the data and information collected through the conversion cookie to create visit statistics for our website. These visit statistics are used to determine the total number of users served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.

The conversion cookie stores personal information, e.g., the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. Google stores these personal data in the United States of America. Google may pass the personal data collected through the technical procedure to third parties.

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, utilizing a corresponding Internet browser setting and thus permanently denying the setting of cookies. Such a setting of the Internet browser would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.

The data subject can object to the interest-based advertisement of Google. Therefore, the data subject must access from each of the browsers by using the link www.google.de/settings/ads and setting the desired settings.

Further information and Google’s applicable data protection provisions may be retrieved at https://www.google.com/intl/en/policies/privacy/.

 

  1. Data protection provisions about the application and use of Instagram

On this website, the controller has integrated components of the service Instagram. Instagram is a service that may be qualified as an audiovisual platform, which allows users to share photos and videos and disseminate such data in other social networks.

The operating company of the services offered by Instagram is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During this technical procedure, Instagram becomes aware of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated into our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.

Instagram receives information via the Instagram component that the data subject has visited our website, provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks the Instagram button. If such a transmission of information to Instagram is not desirable for the data subject, they can prevent this by logging off from their Instagram account before a call-up to our website is made.

Further information and the applicable data protection provisions of Instagram may be retrieved under https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

 

  1. Data protection provisions about the application and use of Jetpack for WordPress

On this website, the controller has integrated Jetpack. Jetpack is a WordPress plug-in that provides additional features to the website operator based on WordPress. Jetpack allows the Internet site operator, among other things, an overview of the site’s visitors. It can also increase visitor numbers by displaying related posts and publications or the ability to share content on the page. Jetpack also optimizes and accelerates the loading of images on the website. In addition, security features are integrated into Jetpack, so a Jetpack-using site is better protected against brute-force attacks.

The operating company of Jetpack Plug-Ins for WordPress is Aut O’Mattic A8C Ireland Ltd., Business Centre, No.1 Lower Mayor Street, International Financial Services Centre, Dublin 1, Ireland.

Jetpack sets a cookie on the information technology system the data subject uses. The definition of cookies is explained above. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Jetpack component was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to submit data through the Jetpack component for analysis purposes to Automattic. During this technical procedure, Automattic receives data to create an overview of website visits. The data obtained in this way serves the analysis of the behavior of the data subject, which has access to the Internet page of the controller and is analyzed to optimize the website. The data collected through the Jetpack component is only used to identify the data subject with a prior obtaining of a separate express consent of the data subject. The data also comes to the notice of Quantcast. Quantcast uses the data for the same purposes as Automattic.

The data subject can, as stated above, prevent the setting of cookies through our website at any time utilizing a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser would also prevent Automattic/Quantcast from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Automattic/Quantcast may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data relating to the use of this Internet site that is generated by the Jetpack cookie as well as the processing of these data by Automattic/Quantcast and the chance to preclude any such. For this purpose, the data subject must press the ‘opt-out’ button under the link https://www.quantcast.com/opt-out/, which sets an opt-out cookie. The opt-out cookie set with this purpose is placed on the information technology system used by the data subject. If the cookies are deleted from the data subject’s system, the data subject must call the link again and set a new opt-out cookie.

However, with the setting of the opt-out cookie, the controller’s websites are no longer entirely usable by the data subject.

The applicable data protection provisions of Automattic may be accessed at https://automattic.com/privacy/. The applicable data protection provisions of Quantcast can be accessed at https://www.quantcast.com/privacy/.

 

  1. Data protection provisions about the application and use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for privacy matters outside of the UNITED STATES.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed at https://developer.linkedin.com/plugins. 

During this technical procedure, LinkedIn gained knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated into our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. If such a transmission of information to LinkedIn is not desirable for the data subject, they may prevent this by logging off from their LinkedIn account before a call-up to our website is made. This occurs regardless of whether the person clicks the LinkedIn button.

LinkedIn provides, under https://www.linkedin.com/psettings/guest-controls, the possibility to unsubscribe from email messages, SMS messages, and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available at https://www.linkedin.com/legal/cookie-policy.

 

  1. Data protection provisions about the application and use of Pinterest

On this website, the controller has integrated components of Pinterest Inc., a social network. A social network is an online social meeting place, an online community allowing users to communicate and interact virtually. A social network may serve as a platform for exchanging opinions and experiences or allow the Internet community to provide personal or company-related information. Pinterest enables social network users to publish, among other things, picture collections, individual pictures, and descriptions on virtual pinboards (so-called pins), which can then be shared by other users (so-called re-pins) or commented on.

The operating company of Pinterest is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

Further information on Pinterest is available at https://pinterest.com/. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Pinterest component (Pinterest plug-in) was integrated, the Internet browser on the information technology system of the data subject automatically prompted to download through the respective Pinterest component a display of the corresponding Pinterest component. During this technical procedure, Pinterest gains knowledge of what specific sub-page of our website is visited by the data subject.

If the data subject is logged in at the same time on Pinterest, Pinterest detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Pinterest component and associated with the respective Pinterest account of the data subject. If the data subject clicks on one of the Pinterest buttons integrated into our website, then Pinterest assigns this information to the personal Pinterest user account of the data subject and stores the personal data.

Pinterest receives information via the Pinterest component that the data subject has visited our website, provided that the data subject is logged in at Pinterest at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Pinterest component. If such a transmission of information to Pinterest is not desirable for the data subject, they may prevent this by logging off from their account before a call-up to our website is made.

The data protection guideline published by Pinterest, available under https://about.pinterest.com/privacy-policy, provides information on the collection, processing, and use of personal data by Pinterest.

 

  1. Data protection provisions about the application and use of Twitter

On this website, the controller has integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g., short messages, which are limited to 280 characters. These short messages are available for everyone, including those not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a broad audience via hashtags, links, or retweets.

The operating company of Twitter is Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07, Ireland.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter. During the course of this technical procedure, Twitter gained knowledge of what specific sub-page of our website was visited by the data subject. The purpose of integrating the Twitter component is to retransmit the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers. Further information about the Twitter buttons is available at https://about.twitter.com/de/resources/buttons.

 

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site, which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated into our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. If such a transmission of information to Twitter is not desirable for the data subject, they may prevent this by logging off from their Twitter account before a call-up to our website is made. This occurs regardless of whether the person clicks on the Twitter component.

The applicable data protection provisions of Twitter may be accessed at https://twitter.com/privacy?lang=en.

 

  1. Data protection provisions about the application and use of YouTube

On this website, the controller has integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, providing free viewing, review, and commenting. YouTube allows you to publish all kinds of videos to access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.

The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained at https://www.youtube.com/yt/about/en/. During this technical procedure, YouTube and Google gained knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in on YouTube, YouTube recognizes with each call-up a sub-page containing a YouTube video in which the subject visited a specific sub-page of our Internet site. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject has visited our website if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If transmitting this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the subject logs off from their own YouTube account before a call-up to our website is made.

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing, and use of personal data by YouTube and Google.

 

  1. Payment Method: Data protection provisions about the use of PayPal as a payment processor

On this website, the controller has integrated components of PayPal. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, representing virtual private or business accounts. PayPal can also process virtual payments through credit cards when a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there are no classic account numbers. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxemburg.

If the data subject chooses “PayPal” as the payment option in the online shop during the ordering process, we automatically transmit the data subject’s data to PayPal. By selecting this payment option, the data subject agrees to transfer personal data required for payment processing.

The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires personal data that are connected with the respective order.

The transmission of the data is aimed at payment processing and fraud prevention. The controller will transfer personal data to PayPal, particularly if a legitimate interest in the transmission is given. The personal data exchanged between PayPal and the controller for processing the data will be transmitted by PayPal to economic credit agencies. This transmission is intended for identity and creditworthiness checks.

PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to the extent that this is necessary to fulfill contractual obligations or for data to be processed in the order.

The data subject can revoke consent for handling personal data at any time from PayPal. A revocation shall not affect personal data, which must be processed, used, or transmitted by (contractual) payment processing.

The applicable data protection provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

 

  1. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations, which are necessary for carrying out pre-contractual measures, for example, concerning inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as to fulfill tax obligations? The processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. For example, this would be the case if a visitor were injured in our company, and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or another third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the abovementioned legal grounds if the processing is necessary for the legitimate interests pursued by our company 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. Such processing operations are particularly permissible because the European legislator specifically mentions them. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

  • The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit, f GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

  • Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted as long as it is no longer necessary to fulfill the contract or initiate a contract.

  • Provision of personal data as a statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which we must subsequently process. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

 

  1. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

 

 

 

 

It was developed by the specialists for LegalTech at Willing & Able, that also developed the digital agreement system. The legal texts in our privacy policy generator have been provided and published by Prof. Dr. h.c. Heiko Jonny Maniero from the German Association for Data Protection and Christian Solmecke from WBS Law.