Meraki Stays

EN

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as “data”) that we process, for which purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Last updated: 15 August 2026

Table of Contents

  • Preamble
  • Controller
  • Overview of Processing Activities
  • Applicable Legal Bases
  • Security Measures
  • Disclosure of Personal Data
  • International Data Transfers
  • General Information on Data Storage and Deletion
  • Rights of Data Subjects
  • Business Services
  • Provision of the Online Offering and Web Hosting
  • Use of Cookies
  • Contact and Inquiry Management
  • Web Analytics, Monitoring and Optimisation
  • Online Marketing
  • Changes and Updates
  • Definitions

Controller

Konstantinos Demirtzis
Weißenburgstr. 16
40476 Düsseldorf

Email address: [email protected]

Telephone: +49 177 5224450

Legal notice: https://meraki-stays.com/impressum

Overview of Processing Activities

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

Types of data processed

  • Master data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Log data.

Categories of data subjects

  • Recipients of services and clients.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Audience measurement.
  • Tracking.
  • Office and organisational procedures.
  • Conversion measurement.
  • Audience formation.
  • Organisational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles containing user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Business processes and commercial procedures.

Applicable Legal Bases

Applicable legal bases under the GDPR: The following provides an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Where more specific legal bases apply in individual cases, we will inform you of these in this privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific provisions, in particular, on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, data transfers and automated decision-making in individual cases, including profiling. In addition, the data protection laws of the individual German federal states may apply.

Security Measures

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

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, securing the availability of and separation of such data. We have also established procedures to ensure the exercise of data-subject rights, the deletion of data and responses to data risks. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principles of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are key technologies for secure data transmission on the internet. They encrypt information transmitted between the website or app and the user’s browser (or between two servers), protecting the data against unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that data transmissions meet high security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL. This indicates to users that their data is transmitted securely and in encrypted form.

Disclosure of Personal Data

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

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in connection with the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be identified from the postal address of the respective provider or where this privacy policy expressly refers to a transfer to third countries), this is always carried out in accordance with the applicable legal requirements.

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

This dual safeguard provides comprehensive protection for your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses provide an additional safeguard. If changes occur within the DPF, the Standard Contractual Clauses serve as a reliable fallback. In this way, we seek to ensure that your data remains adequately protected even in the event of political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular Standard Contractual Clauses, explicit consent or transfers required by law. Information on transfers to third countries and applicable adequacy decisions is available from the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is withdrawn or there is no longer another legal basis for processing. This applies where the original purpose of processing no longer exists or the data is no longer required. Exceptions apply where legal obligations or special interests require longer retention or archiving of the data.

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

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

Where different retention periods or deletion deadlines are stated for the same data, the longest period shall apply. Data that is no longer retained for its original purpose but is retained due to legal requirements or other reasons is processed by us solely for the purposes that justify its retention.

Retention and deletion of data: The following general periods apply to retention and archiving under German law:

  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents required for their understanding (§ 147(1) no. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) no. 1 in conjunction with (4) HGB).
  • 8 years – Accounting records, such as invoices and expense receipts (§ 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO and § 257(1) no. 4 in conjunction with (4) HGB).
  • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters and other documents relevant for taxation, such as hourly wage slips, operating cost sheets, calculation documents and price markings, as well as payroll documents where these are not already accounting records, and cash-register receipts (§ 147(1) nos. 2, 3 and 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
  • 3 years – Data required to take account of potential warranty and damages claims or similar contractual claims and rights, and to process related enquiries, is retained for the regular statutory limitation period of three years, based on prior business experience and customary industry practice (§§ 195, 199 BGB).

Commencement of periods at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within which data is stored, the triggering event is the date on which termination or another form of ending the legal relationship becomes effective.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, arising in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent that you have given at any time.
  • Right of access: You have the right to request confirmation as to whether relevant data is being processed and to obtain access to such data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request completion of data concerning you or correction of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Business Services

We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers and other cooperation partners (collectively, “contractual partners”), for the initiation, performance and handling of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken at the request of the data subject and communications connected with the respective contractual relationship.

The processing serves in particular to fulfil our principal and ancillary contractual obligations. This includes providing the agreed services, any update and information obligations, handling warranty claims and other service disruptions, processing withdrawals, termination of continuing obligations, reversals, refunds and other contract-related declarations and enquiries. This covers both one-off contracts and ongoing contractual relationships.

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

In addition, we process data to safeguard our rights and to comply with legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations and, where applicable, evidence and accountability obligations. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as protecting our business operations and contractual partners against misuse, threats to data, confidential information and other legally protected interests. This may also include engaging external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisers or other agents, where this is necessary for performance of the contract or compliance with legal obligations.

Personal data is disclosed to third parties only insofar as this is necessary for performance of the contract, implementation of pre-contractual measures, protection of legitimate interests or compliance with legal obligations. We provide separate information in this privacy policy about any further processing, in particular for marketing purposes.

We inform contractual partners which data is required in each individual case when the data is collected, for example by appropriate marking in online forms or during personal contact.

Data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent deletion. Statutory retention periods, particularly under commercial and tax law, may require longer storage. Data transmitted in connection with a specific assignment is deleted after completion of the assignment and expiry of any applicable retention periods, provided there are no further legal or contractual obligations requiring storage.

The legal basis for processing is Art. 6(1)(b) GDPR for pre-contractual measures and performance of the respective contractual relationship, and Art. 6(1)(c) GDPR for compliance with legal obligations. Where processing is based on legitimate interests, it is carried out on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves our legitimate interests in proper and efficient business organisation, internal administration and documentation of business transactions, assertion and defence of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and preserving our entrepreneurial capacity to act.

  • Types of data processed: Master data (e.g. 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 telephone numbers); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Recipients of services and clients; prospective customers; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures; business processes and commercial procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Provision of the Online Offering and Web Hosting

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

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files concerning logins, retrieval of data or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from an appropriate server provider (also referred to as a “web host”); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Web host used: Cloud86 B.V. (Cloud86.io), Netherlands.
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the webpages and files accessed, date and time of access, amounts of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, for example to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilisation and stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Deletion of data: Log-file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service that enables content of an online offering, particularly large media files such as graphics or program scripts, to be delivered more quickly and securely using regionally distributed servers connected via the internet; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). CDN and security service used: Cloudflare.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies may be used for various purposes, such as ensuring the functionality, security and convenience of online offerings and analysing visitor flows. We use cookies in accordance with legal requirements. Where required, we obtain users’ consent in advance. Where consent is not required, we rely on our legitimate interests. This applies where storing and reading information is essential in order to provide content and functions expressly requested by users. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent may be withdrawn at any time. We provide clear information about its scope and the cookies used.

Information on data-protection legal bases: Whether we process personal data using cookies depends on consent. Where consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests as explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes the user’s device application (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, login status may be stored and preferred content displayed directly when the user visits a website again. Usage data collected by means of cookies may also be used for audience measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are persistent and may be stored for up to two years.

General information on withdrawal and objection (opt-out): Users may withdraw consent they have given at any time and may also object to processing in accordance with legal requirements, including by using the privacy settings of their browser.

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

Further information on processing activities, procedures and services:

  • Processing of cookie data on the basis of consent: We use a consent-management solution through which users’ consent is obtained for the use of cookies or for the procedures and providers specified within the consent-management solution. This procedure serves to obtain, record, manage and withdraw consent, in particular with regard to the use of cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers named in the consent-management procedure. Users also have the option to manage and withdraw their consent. Consent declarations are stored in order to avoid repeated requests and to be able to demonstrate consent in accordance with legal requirements. Storage takes place on the server and/or in a cookie (a so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or device. Unless specific information is provided regarding providers of consent-management services, the following general information applies: consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of consent (e.g. the relevant categories of cookies and/or service providers), and information about the browser, system and device used; Legal bases: Consent (Art. 6(1)(a) GDPR).
  • Complianz: Storage and management of consents (consent to cookies and data processing), logging of user decisions, display of information on privacy and cookies, enabling users to withdraw or adjust consent; Service provider: Operation on servers and/or computers under its own data-protection responsibility; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/. Further information: An individual user ID, language, types of consent and the time at which consent was given are stored server-side and in a cookie on the user’s device.

Contact and Inquiry Management

When you contact us (e.g. by post, contact form, email, telephone or via social media), and within existing user and business relationships, the information provided by the enquiring persons is processed insofar as this is necessary to respond to contact enquiries and any requested measures.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts and related information, such as authorship information or time of creation); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form); provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing activities, procedures and services:

  • Contact form: When you contact us via our contact form, by email or through other communication channels, we process the personal data transmitted to us in order to respond to and handle the respective matter. This generally includes information such as name, contact details and, where applicable, further information provided to us that is necessary for appropriate handling. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Technical email delivery via Brevo: We use Brevo for the technical transmission of messages from our contact form. The information transmitted via the contact form and technical sending data are processed insofar as this is necessary for technical delivery of the message.

Web Analytics, Monitoring and Optimisation

Web analytics (also referred to as “audience measurement”) is used to evaluate visitor flows to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. Audience analysis allows us, for example, to identify when our online offering, its functions or content are used most frequently or encourage repeat use. It also enables us to identify areas requiring optimisation.

In addition to web analytics, we may also use testing procedures, for example to test and optimise different versions of our online offering or its components.

Unless otherwise stated below, profiles, meaning data combined for a particular usage process, may be created for these purposes and information may be stored in and subsequently read from a browser or device. The information collected includes, in particular, websites visited and elements used on them, as well as technical information such as the browser used, computer system and usage times. Where users have consented to the collection of their location data by us or by providers of services we use, location data may also be processed.

In addition, users’ IP addresses are stored. However, we use an IP-masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. As a general rule, no directly identifying user data (such as email addresses or names) is stored in connection with web analytics, A/B testing and optimisation; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the users’ actual identity, but only the information stored in their profiles for the purposes of the respective procedures.

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

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Audience measurement (e.g. access statistics, recognition of returning visitors); profiles containing user-related information (creation of user profiles); provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Cookies may be stored for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It is used to associate analytics information with a device in order to identify which content users have accessed within one or more usage sessions, which search terms they have used or used again, and how they have interacted with our online offering. The time and duration of use are also stored, as are the sources referring users to our online offering and technical aspects of their devices and browsers.
    Pseudonymous user profiles are created using information from the use of different devices, and cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. Analytics nevertheless provides approximate geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and corresponding ID-based values). For EU traffic, IP address data is used solely to derive this geolocation data and is then immediately deleted. It is not logged, is not accessible and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are carried out on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://business.safety.google/privacy/; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, ad personalisation settings: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
  • Google Tag Manager: We use Google Tag Manager, software provided by Google that enables us to centrally manage so-called website tags through a user interface. Tags are small code elements on our website that are used to record and analyse visitor activity. This technology helps us improve our website and the content offered on it. Google Tag Manager itself does not create user profiles, store cookies containing user profiles or carry out independent analyses. Its function is limited to simplifying and making more efficient the integration and management of tools and services used on our website. Nevertheless, when Google Tag Manager is used, users’ IP addresses are transmitted to Google, which is technically necessary to implement the services we use. Cookies may also be set in this context. However, this data processing only takes place when services are integrated through Tag Manager. For more detailed information about these services and their data processing, please refer to the relevant sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://business.safety.google/privacy/; Data Processing Agreement:
    https://business.safety.google/adsprocessorterms. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).

Online Marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on users’ potential interests and the measurement of its effectiveness.

For these purposes, user profiles are created and stored in a file (the so-called “cookie”) or similar procedures are used to store information about users that is relevant to the display of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, the computer system, usage times and functions used. Where users have consented to the collection of their location data, this may also be processed.

Users’ IP addresses are also stored. However, we use available IP-masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. As a general rule, no directly identifying user data (such as email addresses or names) is stored as part of online marketing procedures; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing procedures know the users’ actual identity, but only the information stored in their profiles.

The information contained in profiles is generally stored in cookies or by means of similar procedures. These cookies may later also be read on other websites that use the same online marketing procedure, analysed for the purpose of displaying content, supplemented with additional data and stored on the server of the online marketing procedure provider.

In exceptional cases, directly identifying data may be associated with profiles, particularly where users are, for example, members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. Please note that users may enter into additional agreements with providers, for example by giving consent during registration.

As a rule, we only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurement, we can determine which of our online marketing procedures resulted in a conversion, for example the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

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

Information on withdrawal and objection:

We refer to the privacy notices of the respective providers and the objection options (so-called “opt-out”) specified for those providers. Where no explicit opt-out option is stated, you may disable cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered for the respective regions:

a) Europe: https://youronlinechoices.eu/.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-regional: https://optout.aboutads.info.

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Audience measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest-/behaviour-based profiling, use of cookies); audience formation; marketing; profiles containing user-related information (creation of user profiles); conversion measurement (measurement of the effectiveness of marketing measures).
  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion”. Cookies may be stored for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Google Ads and conversion measurement: Online marketing procedure for placing content and advertisements within the service provider’s advertising network (e.g. in search results, videos, websites, etc.) so that they are displayed to users who are presumed to have an interest in the advertisements. We also measure ad conversions, i.e. whether users interacted with the advertisements and used the advertised offers (so-called conversions). However, we receive only anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://business.safety.google/privacy/; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and Standard Contractual Clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

Changes and Updates

We ask you to review the content of our privacy policy regularly. We update the privacy policy whenever changes to the data processing activities we carry out make this necessary. We will inform you if changes require any action on your part (e.g. consent) or another form of individual notification.

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

Definitions

This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their statutory definitions apply. The following explanations are primarily intended to aid understanding.

  • Master data: Master data includes essential information required to identify and manage contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data provides the basis for formal interaction between persons and services, institutions or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on different platforms and media. Content data is not limited to the content itself but may also include metadata providing information about the content, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organisations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as communication identifiers such as social-media handles and instant-messaging identifiers.
  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure used to determine the effectiveness of marketing measures. As a rule, a cookie is stored on users’ devices on websites where the marketing measures take place and is then retrieved again on the target website. This allows us, for example, to determine whether advertisements placed by us on other websites were successful.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories containing information about how data is processed, transmitted and managed. Metadata, also known as data about data, includes information describing the context, origin and structure of other data. It may include details such as file size, creation date, author of a document and change histories. Communication data records the exchange of information between users through various channels, such as email traffic, call logs, social-network messages and chat histories, including the persons involved, timestamps and transmission routes. Procedural data describes processes and workflows within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to trace and review operations.
  • Usage data: Usage data refers to information recording how users interact with digital products, services or platforms. It includes a wide range of information showing how users use applications, which functions they prefer, how long they remain on particular pages and which paths they take through an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Usage data also plays an important role in identifying trends, preferences and potential problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles containing user-related information: The processing of “profiles containing user-related information”, or “profiles” for short, encompasses any form of automated processing of personal data in which personal data is used to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content) (for example interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
  • Log data: Log data is information about events or activities recorded in a system or network. Such data typically includes information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, monitor security or create performance reports.
  • Audience measurement: Audience measurement (also referred to as web analytics) is used to evaluate visitor flows to an online offering and may include visitors’ behaviour or interests in particular information, such as website content. Audience analysis enables operators of online offerings to identify, for example, when users visit their websites and which content interests them, allowing website content to be better adapted to visitors’ needs. Pseudonymous cookies and web beacons are often used for audience measurement to recognise returning visitors and obtain more precise analyses of use of an online offering.
  • Tracking: “Tracking” refers to the ability to trace user behaviour across multiple online offerings. As a rule, behavioural and interest information relating to the online offerings used is stored in cookies or on the servers of providers of tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, including collection, evaluation, storage, transmission and deletion.
  • Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This data category is essential for managing and fulfilling contractual obligations and includes both identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include contract start and end dates, the type of agreed services or products, price agreements, payment terms, termination rights, renewal options and special terms or clauses. It serves as the legal basis for the relationship between the parties and is important for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. This data is important for e-commerce, online banking and other forms of financial transactions. It includes details such as credit-card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also include information about payment status, chargebacks, authorisations and fees.
  • Audience formation: Audience formation (“Custom Audiences”) refers to determining target groups for advertising purposes, for example for displaying advertisements. A user’s interest in certain products or topics on the internet may, for example, indicate that the user is interested in advertisements for similar products or for the online shop in which the products were viewed. “Lookalike Audiences” (or similar audiences) refers to showing content considered suitable to users whose profiles or interests are presumed to correspond to those of the users on whose basis the profiles were formed. Cookies and web beacons are generally used to create Custom Audiences and Lookalike Audiences.

Created with the free Datenschutz-Generator.de by Dr Thomas Schwenke

Editing note: The source text created with Datenschutz-Generator.de was subsequently supplemented only with information on Cloud86.io, Cloudflare and Brevo, as well as the contact email address [email protected].