Privacy Policy

Preamble

With the following privacy policy we would like to inform you about which types of your personal data (hereinafter also referred to in short as "data") 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 course 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.

As of: 21 February 2026

Table of Contents

Controller

Velena UG (haftungsbeschränkt)
Konrad-Adenauer Str. 27
63225 Langen
Deutschland

Authorised representatives: Tim Lorenz

Email address: date@avanoire.com

Legal notice: https://avanoire.agency/impressum

Overview of processing operations

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects concerned.

Types of data processed

  • Inventory 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.
  • Interested parties.
  • Communication partners.
  • Users.
  • Business and contractual partners.

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Reach measurement.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Public relations.
  • Business processes and economic procedures.

Applicable legal bases

Applicable legal bases under the GDPR:Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 Abs. 1 S. 1 lit. a) DSGVO) - The data subject has given their consent to the processing of the personal data concerning them for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO) - The 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 Abs. 1 S. 1 lit. c) DSGVO) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO) - the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that the interests, fundamental rights and freedoms of the data subject that require the protection of personal data do not override those interests.

National data protection regulations in Germany:In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, 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 the legal requirements and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, assurance of availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data and responses to threats to the data. In addition, 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 principle of data protection through technology design and through privacy-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and 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 signalled 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, it may happen that such data is transferred to, or disclosed to, other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: Insofar as we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, bodies or companies (which becomes apparent from the postal address of the respective provider or where the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission of 10.07.2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses take effect as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of any political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses exist. Further information on the DPF and a list of certified companies can be found on the website of the US 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, express consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and erasure

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

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the pursuit of legal claims or for 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 erasure of data that applies specifically to certain processing operations.

Where there are several indications regarding the retention period or erasure deadlines for a piece of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose but rather on the basis of legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

Retention and erasure 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, as well as the work instructions and other organizational documents required to understand them (§ 147 Abs. 1 Nr. 1 i.V.m. Abs. 3 AO, § 14b Abs. 1 UStG, § 257 Abs. 1 Nr. 1 i.V.m. Abs. 4 HGB).
  • 8 years - accounting vouchers, such as invoices and expense receipts (§ 147 Abs. 1 Nr. 4 und 4a i.V.m. Abs. 3 Satz 1 AO sowie § 257 Abs. 1 Nr. 4 i.V.m. Abs. 4 HGB).
  • 6 years - other business documents: received commercial or business letters, reproductions of the commercial or business letters sent, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll accounting documents, insofar as they are not already accounting vouchers, and cash register strips (§ 147 Abs. 1 Nr. 2, 3, 5 i.V.m. Abs. 3 AO, § 257 Abs. 1 Nr. 2 u. 3 i.V.m. Abs. 4 HGB).
  • 3 years - data required in order to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Commencement of the period at the end of the year: If a period does not begin expressly on a specific date and lasts at least one year, 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 in the context of which data is stored, the event triggering the period is the point in time at which the termination or other ending of the legal relationship takes effect.

Data subject rights

Data subject rights under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 Abs. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose 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 consent given at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the rectification of incorrect data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with the legal requirements, to request a 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 accordance with the legal requirements, in a structured, commonly used and machine-readable format, 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 requirements of the GDPR.

Business services

We process personal data of our contractual and business partners, such as customers, clients, interested parties, suppliers and other cooperation partners (collectively "contractual partners"), for the purpose of initiating, performing and processing contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.

The processing serves in particular the fulfilment of our main and ancillary contractual obligations. These include the provision of the agreed services, any update and information obligations, the handling of warranty claims and other performance disruptions, the processing of withdrawals, terminations of continuing obligations, reversals, refunds, as well as the processing of other contract-related declarations and inquiries. This covers both one-off contracts and ongoing contractual relationships.

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

In addition, we process the data to safeguard our rights and to fulfil legal obligations. This includes in particular commercial and tax law retention obligations, 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 in the protection of our business operations and our contractual partners against misuse, threats to data, secrets and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the performance of the contract or for the fulfilment of legal obligations.

Personal data is disclosed to third parties only insofar as this is necessary for the performance of the contract, the implementation of pre-contractual measures, the safeguarding of legitimate interests or the fulfilment of legal obligations. We inform you separately about processing that goes beyond this, in particular for marketing purposes, within this privacy policy.

We inform the contractual partners of which data is required in individual cases in the course of the data collection, for example in online forms by means of corresponding marking or in personal contact.

The data is erased as soon as it is no longer required for the aforementioned purposes and no legal retention obligations conflict with this. Statutory retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the course of a specific order is erased by us after completion of the order and expiry of any retention periods, provided that no further legal or contractual storage obligations exist.

The legal basis for the processing is Art. 6 Abs. 1 lit. b DSGVO for the implementation of pre-contractual measures and for the fulfilment of the respective contractual relationship, as well as Art. 6 Abs. 1 lit. c DSGVO for the fulfilment of legal obligations. Insofar as the processing is based on legitimate interests, it takes place on the basis of Art. 6 Abs. 1 lit. f DSGVO. Insofar as the processing is based on Art. 6 Abs. 1 lit. f DSGVO, it takes place to safeguard our legitimate interests in a proper and efficient business organization, the internal administration and documentation of business transactions, the enforcement and defence of legal claims, ensuring IT and data security, the prevention of misuse and fraud, as well as the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in maintaining our entrepreneurial ability to act.

  • Processed data types: Inventory data (e.g. the full name, home 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; interested parties. Business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfilment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and economic procedures.
  • Retention and erasure: Erasure in accordance with the information provided in the section "General information on data storage and erasure".
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO); Legal obligation (Art. 6 Abs. 1 S. 1 lit. c) DSGVO). Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Further notes on processing operations, procedures and services:

  • Agency services:We process the data of our customers in the context of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO).

Provision of the online offering and web hosting

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

  • Processed data types: Usage data (e.g. page views and dwell time, 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, timestamps, identification numbers, persons involved); log data (e.g. log files concerning logins or the retrieval of data or access times.). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or the time of creation).
  • 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 devices (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 bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Further notes on processing operations, procedures and services:

  • Provision of the online offering / hosting and content delivery network (CDN):Our online offering is operated with a hosting provider that provides storage space, computing capacity and the delivery of content via a globally distributed CDN; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://vercel.com; Privacy policy: https://vercel.com/legal/privacy-policy; Basis for third-country transfers: Standard contractual clauses.
  • Collection of access data and log files:Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, volumes of data transferred, notification of successful retrieval, 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. The server log files can be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO). Erasure of data: Log file information is stored for a maximum period of 30 days and then erased or anonymized. Data whose further retention is required for evidentiary purposes is exempt from erasure until the definitive clarification of the respective incident.
  • Object storage for application and photo uploads:For the receipt and storage of documents and photos submitted via the partner/application form, we use an S3-compatible object storage with server location in Frankfurt am Main (EU); Service provider: DigitalOcean LLC, 105 Edgeview Drive, Suite 425, Broomfield, CO 80021, USA (server location Frankfurt am Main, EU); Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO), Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO); Website: https://www.digitalocean.com; Privacy policy: https://www.digitalocean.com/legal/privacy-policy.
  • Sending and receiving email:Inquiries from the forms as well as further communication are processed by email via our email and hosting service provider; Service provider: IONOS SE, Elgendorfer Straße 57, 56410 Montabaur, Deutschland; Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO), Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/datenschutzerklaerung/.
  • Spam protection for the forms (Captcha):To protect our forms against automated entries (bots/spam), we use a privacy-friendly captcha service that works without cookies and without tracking; Service provider: Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Deutschland; Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://friendlycaptcha.com; Privacy policy: https://friendlycaptcha.com/legal/privacy-end-users/.

Use of cookies

The term "cookies" refers to functions that store information on users' devices and read information from them. Cookies can also be used in relation to various concerns, for example for purposes of the functionality, security and comfort of online offerings, as well as the creation of analyses of visitor flows. We use cookies in accordance with the legal provisions. To this end, we obtain the prior consent of users where required. Where consent is not necessary, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about its scope and which cookies are used.

Notes on the data protection legal bases:Whether we process personal data with the help of cookies depends on consent. Where consent exists, 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, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are erased at the latest after a user leaves an online offering and closes their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be stored and preferred content displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Insofar as we do not provide users with explicit information on the type and storage period of cookies (e.g. in the context of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

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

  • Processed data types: Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to respond to the contact inquiries and any requested measures.

  • Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or the time of creation). Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure in accordance with the information provided in the section "General information on data storage and erasure".
  • Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO). Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO).

Further notes on processing operations, procedures and services:

  • Contact form:When contacting us via our contact form, by email or other means of communication, we process the personal data transmitted to us in order to respond to and handle the respective concern. This generally includes information such as name, contact information and, where applicable, further information that is communicated to us and is necessary for appropriate handling. We use this data exclusively for the stated purpose of making contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b) DSGVO), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Web analysis, monitoring and optimization

For the statistical evaluation of the visitor flows of our online offering, we use a cookieless, privacy-friendly web analysis. In doing so, no cookies are set, no cross-device user profiles are created and no personal data such as full IP addresses is stored permanently. The evaluation is carried out in aggregated and anonymized form (e.g. page views, dwell time, referral sources, approximate region, browser and device type used).

The analysis script is delivered via our own domain (proxy), so that no direct connections of visitors to third-party servers arise for the purpose of reach measurement.

Note on legal bases: Since, for analysis purposes, no information requiring consent is stored on or read from the device, the processing takes place on the basis of our legitimate interests in a statistical, data-minimizing reach measurement and the optimization of our online offering.

  • Processed data types: Usage data (e.g. page views, dwell time, referral sources); meta, communication and procedural data (e.g. aggregated technical information, approximate region).
  • Data subjects: Users (e.g. website visitors).
  • Purposes of processing: Reach measurement (aggregated access statistics); optimization of the online offering.
  • Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).
  • Service provider: Plausible Analytics – Plausible Insights OÜ, Västriku tn 2, 50403 Tartu, Estland; Website: https://plausible.io; Privacy policy: https://plausible.io/data-policy.

Presence in social networks (social media)

We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.

We point out that user data may be processed outside the area of the European Union in this context. This may result in risks for users, because, for example, the enforcement of users' rights could be made more difficult.

Furthermore, the data of users within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For this purpose, cookies are generally stored on the users' computers, in which the usage behaviour and interests of the users are stored. In addition, data may also be stored in the usage profiles independently of the devices used by the users (in particular if they are members of the respective platforms and are logged in there).

For a detailed presentation of the respective forms of processing and the possibilities to object (opt-out), we refer to the privacy policies and information of the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the latter each have access to the user data and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as details of authorship or the time of creation). Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, 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 and legitimate interests: Communication; feedback (e.g. collecting feedback via online form). Public relations.
  • Retention and erasure: Erasure in accordance with the information provided in the section "General information on data storage and erasure".
  • Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Further notes on processing operations, procedures and services:

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

Amendment and update

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and we ask you to check the details before making contact.

Definitions of terms

In this section you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Inventory data: Inventory data comprises essential information necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions or systems, by enabling unambiguous assignment and communication.
  • Content data: Content data comprises information generated in the course of the creation, editing and publication of content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the manner in which 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 of the file size, the creation date, the author of a document and the modification histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, as well as audit logs used to trace and review operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data comprises a wide range of information that shows how users use applications, which functions they prefer, how long they spend on certain pages and which paths they take to navigate through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible 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 with user-related information: The processing of "profiles with user-related information", or "profiles" for short, comprises any kind of automated processing of personal data consisting in using such personal data 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, etc.) (e.g. interests in certain content or products, the click behaviour on a website or the whereabouts). 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 about the use or operation of a system. Log data is often used to analyse system problems, for security monitoring or for the creation of performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may comprise the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their web pages and which content they are interested in. As a result, they can, for example, better adapt the content of the web pages to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • 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" is any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collecting, evaluating, storing, transmitting or erasing.
  • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the administration and fulfilment of contractual obligations and comprises both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, 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 decisive for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of decisive importance for electronic commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and invoice information. Payment data may also contain information about the payment status, chargebacks, authorizations and fees.

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