Privacy Policy

Preamble

The following privacy policy is intended to explain what types of personal data (hereinafter also referred to simply as “data”) we process, for what purposes, and to what extent. This Privacy Policy applies to all processing of personal data carried out by us, both in connection with the provision of our services and, in particular, on our websites, in mobile applications and on external online platforms, such as our social media profiles (hereinafter collectively referred to as the "Online Services").

 

The terms used are gender-neutral.

Date: 27 October 2026

Table of contents

•    Preamble

•    Data controller

•    Overview of processing activities

•    Relevant legal bases

•    Security measures

•    Disclosure of personal data

•    International data transfers

•    General information on data storage and deletion

•    Rights of data subjects

•    Provision of the online service and web hosting

•    Use of cookies

•     Contact and enquiry management

•    Newsletters and electronic notifications

•    Social media presence

•    Plug-ins, embedded functions and content

•    Changes and updates

•    Definitions of terms

 

Data controller

JHE LIFE - Melanie Naumann

c/o CENTER

Kobboldstr. 1

86551 Aichach

E-Mail-Adresse: jhe.breathwork@gmail.com

 

Overview of data processing

The following overview summarises the types of data processed and the purposes of such processing, and identifies the data subjects.

Types of data processed

•    Personal details.

•    Location data.

•    Contact details.

•    Content data.

•    Usage data.

•    Meta, communication and procedural data.

•    Log data.

Categories of data subjects

•    Communication partners.

•    Users.

Purposes of processing

•    Communication.

•    Security measures.

•    Direct marketing.

•    Organisational and administrative procedures.

•    Feedback.

•    Marketing.

•    Profiles containing user-related information.

•    Provision of our online services and user-friendliness.

•    IT infrastructure.

•    Public relations.

Relevant legal bases

Relevant legal bases under the GDPR: Below is 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 country of residence or our country of domicile. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

•    Consent (Article 6(1)(a) of the GDPR) – The data subject has given consent to the processing of personal data relating to them for a specific purpose or for several specific purposes.

•    Performance of a contract and pre-contractual enquiries (Article 6(1)(b) of the GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the data subject’s request.

•    Legitimate interests (Article 6(1)(f) of the GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests, fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG).

The BDSG contains, in particular, specific provisions 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, and the transfer of data, as well as automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Security measures

In accordance with legal requirements, and taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the 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, and disclosure of the data, ensuring its availability and its segregation. Furthermore, we have established procedures to ensure that data subjects’ rights are upheld, that data is deleted, and that appropriate action is taken in the event of a data breach.

Furthermore, we take the protection of personal data into account right from the development and selection of hardware, software and processes, in accordance with the principle of data protection by design and through privacy-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission over the internet. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between a website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the enhanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transfer of personal data

In the course of our processing of personal data, such data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or individuals. Recipients of this 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 legal requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.

International data transfers

Data processing in third countries: Where we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where 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 by the postal address of the respective provider or if the privacy policy expressly refers to data transfers to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a safe legal framework by an adequacy decision of the European Commission dated 10 July 2023. In addition, we have entered into standard contractual clauses with the relevant providers, which comply with the European Commission’s requirements and set out contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, whilst the standard contractual clauses serve as an additional safeguard. Should any changes arise within the framework of the DPF, the standard contractual clauses act as a reliable fallback option. In this way, we ensure that your data remains adequately protected at all times, even in the event of any political or legal changes.

For individual service providers, we will 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 US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

Appropriate safeguards apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law.

Information on transfers to third countries and applicable adequacy decisions can be found on the European Commission’s website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and erasure

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are withdrawn or there are no further legal grounds for processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply where legal obligations or specific interests require the data to be retained or archived for a longer period.

In particular, data that must be retained for commercial or tax law reasons, or where storage is necessary for legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the retention and erasure of data that applies specifically to certain processing operations.

Where there are multiple references to the retention period or erasure deadlines for a particular piece of data, the longest period shall always apply.

We process data that is no longer retained for its originally intended purpose, but rather due to legal requirements or other reasons, exclusively for the purposes that justify its retention.

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

• 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the working instructions and other organisational documents necessary for their understanding (Section 147(1)(1) in conjunction with (3) of the German Fiscal Code (AO), Section 14b(1) of the German Value Added Tax Act (UStG), Section 257(1)(1) in conjunction with (4) of the German Commercial Code (HGB)).

• 8 years – accounting documents, such as invoices and expense receipts (Section 147(1)(4) and (4a) in conjunction with (3), first sentence, of the German Fiscal Code (AO) and Section 257(1)(4) in conjunction with (4) of the German Commercial Code (HGB)).

• 6 years – Other business documents: incoming commercial or business correspondence, copies of outgoing commercial or business correspondence, other documents insofar as they are relevant for taxation purposes, e.g. hourly pay slips, cost accounting sheets, costing documents, price labels, as well as payroll records, provided they are not already accounting documents, and cash register receipts (Section 147(1)(2), (3) and (5) in conjunction with (3) of the German Fiscal Code (AO), Section 257(1)(2) and (3) in conjunction with (4) of the German Commercial Code (HGB)).

• 3 years – Data required to address potential warranty and compensation claims or similar contractual claims and rights, and to process related enquiries, based on previous business experience and standard industry practices, will be stored for the duration of the standard statutory limitation period of three years (Sections 195 and 199 of the German Civil Code (BGB)).

Commencement of the limitation period at the end of the year: If a limitation period does not expressly commence on a specific date and is at least one year in duration, it shall automatically commence at the end of the calendar year in which the event triggering the limitation period occurred. In the case of ongoing contractual relationships within the scope of which data is stored, the event triggering the limitation period is the date on which the termination or other termination of the legal relationship takes effect.

Rights of data subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.

• Right to withdraw consent: You have the right to withdraw any consent you have given at any time.

• Right of access: You have the right to request confirmation as to whether data concerning you 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 that data concerning you be completed or that incorrect data concerning you be rectified.

• Right to erasure and restriction of processing: In accordance with the relevant legal provisions, you have the right to request that data relating to you be erased without delay, or alternatively, in accordance with the relevant legal provisions, to request a restriction on the processing of such data.

• Right to data portability: You have the right, in accordance with legal requirements, to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request that it be transferred 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 the place of the alleged infringement, if you consider that the processing of your personal data infringes the provisions of the GDPR.

Provision of the online service and web hosting

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

• Types of data processed: usage data (e.g. page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved); Log data (e.g. log files relating to logins, data retrieval or access times); Content data (e.g. textual or visual messages and posts, as well as related information such as details of authorship or time of creation).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.

• Retention and erasure: Erasure in accordance with the information provided in the section ‘General information on data storage and erasure’.

• Legal basis: Legitimate interests (Article 6(1)(f) of the GDPR).

Further information on processing operations, procedures and services:

• Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a relevant server provider (also known as a “web host”); Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

• Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, a 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, on the one hand, for security purposes, e.g. to prevent server overload (particularly in the event of malicious attacks, known as DDoS attacks), and, on the other hand, to ensure server capacity and stability; legal basis: legitimate interests (Article 6(1)(f) of the GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and is then deleted or anonymised. Data that must be retained for evidential purposes is exempt from deletion until the relevant incident has been fully resolved.

• Wix: Hosting and software for the creation, provision and operation of websites, blogs and other online services; Service provider: Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://de.wix.com/; Privacy policy: https://de.wix.com/about/privacy; Data processing agreement: https://www.wix.com/about/privacy-dpa-users. Basis for transfers to third countries: Data Privacy Framework (DPF).

Use of Cookies

The term “cookies” refers to functions that store and retrieve information on users’ devices. Cookies may also be used for various purposes, such as ensuring the functionality, security and user-friendliness of online services, as well as for analysing visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the user’s consent in advance where necessary. Where consent is not required, we rely on our legitimate interests. This applies where the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent may be withdrawn at any time. We provide clear information about the scope of this and which cookies are used.

Notes on the legal basis under data protection law: 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, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest once a user has left an online service and closed their device (e.g. browser or mobile app).

• Persistent cookies: Persistent cookies remain stored even after the device has been closed. This allows, for example, the login status to be saved and preferred content to be displayed directly when the user visits a website again. Similarly, user data collected via cookies may be used for audience measurement. Unless we provide users with explicit information regarding the type and storage duration of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period may be up to two years.

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

• Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).

• Data subjects: Users (e.g. website visitors, users of online services).

• Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further information on processing operations, procedures and services:

• Processing of cookie data based on consent: We use a consent management solution to obtain users’ consent to the use of cookies or to the procedures and providers specified within the consent management solution. This procedure serves to obtain, log, manage and revoke consents, in particular with regard to the use of cookies and similar technologies used to store, read and process information on users’ end 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 operations and providers mentioned in the consent management procedure. Users also have the option to manage and withdraw their consents. The declarations of consent are stored to avoid repeated requests and to be able to provide evidence of consent in accordance with legal requirements. Consent is stored on the server and/or in a cookie (known as an opt-in cookie) or using comparable technologies, in order to be able to link the consent to a specific user or their device. Unless specific details regarding the providers of consent management services are available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, details regarding the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the end device used; legal basis: consent (Art. 6(1)(a) GDPR).

Contact and enquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the context of existing user and business relationships, the details of the enquirers are processed to the extent necessary to respond to contact enquiries and any requested actions.

• Types of data processed: contact details (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image-based messages and posts, as well as related information such as details of authorship or the time of creation). Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved).

• Data subjects: Communication partners.

• Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form). Provision of our online services and user-friendliness.

• Retention and erasure: Erasure in accordance with the information in the section “General information on data storage and erasure”.

• Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).

Further information on processing operations, 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 provided to us in order to respond to and handle your enquiry. This generally includes details such as your name, contact details and, where applicable, any further information provided to us that is necessary for the appropriate handling of your enquiry. We use this data exclusively for the stated purpose of establishing 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).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) exclusively with the consent of the recipients or on a legal basis. Where the content of the newsletter is specified during the subscription process, this content is decisive for the user’s consent. To subscribe to our newsletter, providing your email address is usually sufficient. However, in order to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter, or to provide further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to demonstrate that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently comply with objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out correctly. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.

Content:

Information about us, our services, promotions and offers.

• Types of data processed: Personal details (e.g. full name, home address, contact details, customer number, etc.); contact details (e.g. postal and email addresses or telephone numbers); metadata, communication and transaction data (e.g. IP addresses, timestamps, identification numbers, individuals involved).

• Data subjects: Communication partners.

• Purposes of processing: Direct marketing (e.g. by email or post).

• Legal basis: Consent (Art. 6(1)(a) GDPR).

• Right to object (opt-out): You may unsubscribe from our newsletter at any time, i.e. withdraw your consent or object to receiving further issues. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you may use one of the contact options listed above, preferably by email.

Social media presence

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

We would like to point out that user data may be processed outside the European Union in this context. This may entail risks for users, as it could, for example, make it more difficult to enforce their rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behaviour and the resulting interests. These profiles may in turn be used, for instance, to display advertisements within and outside the networks that are presumed to correspond to users’ interests. Consequently, cookies are usually stored on users’ computers, in which their usage behaviour and interests are recorded. Furthermore, data may also be stored in these user profiles regardless of the devices used by the users (particularly if they are members of the respective platforms and are logged in there).

For a detailed description of the specific forms of data processing and the options for opting out, please refer to the privacy policies and information provided by the operators of the respective networks.

We would also like to point out that requests for information and the exercise of data subjects’ rights are most effectively handled by the providers themselves. Only the latter have access to the user data and can take appropriate action and provide information directly. Should you nevertheless require assistance, you may contact us.

• Types of data processed: Contact details (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image-based messages and posts, as well as related information such as details of authorship or the time of creation); Usage data (e.g. page views and time spent on site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Communication; feedback (e.g. collecting feedback via online forms). Public relations.

• Storage and deletion: Deletion in accordance with the information provided in the section ‘General information on data storage and deletion’.

• Legal basis: Legitimate interests (Article 6(1)(f) of the GDPR).

Further information on processing operations, procedures and services:

• Instagram: Social network enabling the sharing of photos and videos, commenting on and favouriting posts, sending messages, and following profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF).

• LinkedIn: Social network – Together with LinkedIn Ireland Unlimited Company, we are responsible for the collection (but not the further processing) of visitor data used to generate the “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchical level, company size and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy. We have entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which sets out in particular the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users may, for example, submit requests for access or erasure directly to LinkedIn). Users’ rights (in particular the right to access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company, LinkedIn Corporation, in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plug-ins, embedded functions and content

We incorporate functional and content elements into our online offering that are sourced from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or city maps (hereinafter collectively referred to as “content”).

The integration always requires that the third-party providers of this content process the user’s IP address, as they would be unable to send the content to the user’s browser without it. The IP address is therefore necessary for the display of this content or these functions. We endeavour to use only content where the respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These ‘pixel tags’ enable information, such as visitor traffic on the pages of this website, to be analysed. The pseudonymous information may also be stored in cookies on the user’s device and may include, amongst other things, technical information about the browser and operating system, referring websites, the time of visit, and further details regarding the use of our online service, but may also be linked to such information from other sources.

Notes on legal bases: Where we ask users for their consent to the use of third-party providers, the legal basis for data processing is this consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. an interest in providing efficient, cost-effective and user-friendly services). In this context, we would also like to draw your attention to the information regarding the use of cookies in this privacy policy.

• Types of data processed: usage data (e.g. page views and time spent on the site, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, persons involved). Location data (information regarding the geographical position of a device or a person).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Provision of our online services and user-friendliness; marketing. Profiles containing user-related information (creation of user profiles).

• Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.).

• Legal basis: Consent (Article 6(1)(a) of the GDPR). Legitimate interests (Article 6(1)(f) of the GDPR).

Further information on processing operations, procedures and services:

• Google Maps: We integrate maps from the ‘Google Maps’ service provided by Google. The data processed may include, in particular, users’ IP addresses and location data; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for transfers to third countries: Data Privacy Framework (DPF).

• Instagram plugins and content: Instagram plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online service within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt, in the context of a transfer (but not the further processing), of “event data” which Facebook collects via Instagram functions (e.g. content embedding functions) executed on our online service, or which it receives in the context of a transfer, for the following purposes: a) Displaying content and advertising information that corresponds to users’ presumed interests; b) Delivery of commercial and transaction-related messages (e.g. contacting users via Facebook Messenger); c) Improving ad delivery and personalising features and content (e.g. improving the identification of content or advertising information likely to match users’ interests). We have entered into a specific agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum), which specifically sets out the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil data subjects’ rights (i.e. users may, for example, submit requests for information or deletion directly to Facebook). Note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum). Users’ rights (in particular the right to access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.

• LinkedIn plugins and content: LinkedIn plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this website within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Basis for transfers to third countries: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.linkedin.com/legal/l/dpa). Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Amendments and updates

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

Where we provide addresses and contact details of companies and organisations in this privacy policy, please note that these details may change over time and we ask you to check them before making contact.

Definitions

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

• Master data: Master data comprises essential information required for the identification and management of contractual partners, user accounts, profiles and similar records. This data may include, amongst other things, personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions or systems by enabling unique identification and communication.

• Content data: Content data comprises information generated during the creation, editing and publication of content of all kinds. This category of data may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates

• Contact data: Contact data is essential information that enables communication with individuals or organisations. It includes, amongst other things, telephone numbers, postal addresses and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.

• Meta, communication and operational data: Meta, communication and operational data are categories that contain information about how data is processed, transmitted and managed. Meta data, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email correspondence, call logs, social media messages and chat histories, including the individuals involved, timestamps and transmission routes. Process data describes the processes and procedures within systems or organisations, including workflow documentation, transaction and activity logs, as well as audit logs used to track and verify operations.

• Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data encompasses a wide range of information that reveals how users utilise applications, which features they prefer, how long they spend on specific pages and the paths they take when navigating through an application. Usage data may also include frequency of use, timestamps of activities, 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. Furthermore, usage data plays a crucial 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 referred to as the ‘data subject’); a natural person is regarded as identifiable if they 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. a 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 that involves using such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the nature of the profiling, this may include various information regarding demographics, behaviour and interests, such as interaction with websites and their content, etc.) or to predict them (e.g. interests in specific content or products, clicking 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 that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details regarding the use or operation of a system. Log data is often used to analyse system issues, for security monitoring or to generate performance reports.

• Location data: Location data is generated when a mobile device (or another device capable of determining its location) connects to a mobile network cell, a Wi-Fi network or similar technical means and location-determination functions. Location data is used to indicate the specific geographical position on Earth at which the device is located. Location data can, for example, be used to display map functions or other location-dependent information.

• Controller: The term ‘controller’ refers to 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 which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission or erasure.