Version 2024-09-19

Privacy & cookie statement

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

The terms used are not gender-specific.

Controller

Overview of Processing Operations

Relevant Legal Bases

Security Precautions

Transmission of Personal Data

International Data Transfers

Rights of Data Subjects

Provision of Online Services and Web Hosting

Registration, Login and User Account

Contact and inquiry management

Communication via Messenger

Newsletter and Electronic Communications

Commercial communication by E-Mail, Postal Mail, Fax orTelephone

Web Analysis, Monitoring and Optimization

Profiles in Social Networks (Social Media)

Plugins and embedded functions and content

Changes and Updates

Terminology and Definitions

1. Controller

Mike Brauner
polardots.studio GmbH
Katharinenstr 30
20457 Hamburg
Germany
E-mail address: info@polardots.studio
Phone: +49 40 593625190

2. Overview of processing operations

The following table summarises the types ofdata processed, the purposes for which they are processed and the concerneddata subjects.Categories of Processed Data Inventory data. Contact data. Content data. Usage data. Meta, communication and process data. Log data. Categories of Data Subjects Communication partner. Users. Business and contractual partners.Purposes of Processing Provision of contractual services and fulfillment of contractual obligations. Communication. Security measures. Direct marketing. Web Analytics. Office and organisational procedures. Organisational and Administrative Procedures. Content Delivery Network (CDN). Feedback. Marketing. Profiles with user-related information. Provision of our online services and usability. Information technology infrastructure. Public relations. Sales promotion.

3. Relevant legal bases

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

Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate Interests (Article 6 (1) (f) GDPR) - the processing is necessary for the protection of the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require the protection of personal data, do not prevail.

National data protection regulations in Germany: In addition to the data protectionregulations of the GDPR, national regulations apply to data protection inGermany. This includes in particular the Law on Protection against Misuse ofPersonal Data in Data Processing (Federal Data Protection Act - BDSG). Inparticular, the BDSG contains special provisions on the right to access, theright to erase, the right to object, the processing of special categories ofpersonal data, processing for other purposes and transmission as well asautomated individual decision-making, including profiling. Furthermore, dataprotection laws of the individual federal states may apply.

Relevant legal basis according to theSwiss Data Protection Act: If you are located inSwitzerland, we process your data based on the Federal Act on Data Protection(referred to as "Swiss DPA"). Unlike the GDPR, for instance, theSwiss DPA does not generally require that a legal basis for processing personaldata be stated and that the processing of personal data is conducted in goodfaith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss DPA).Furthermore, we only collect personal data for a specific purpose recognizableto the data subject and process it only in a manner compatible with thispurpose (Art. 6 para. 3 of the Swiss DPA).

Reference to the applicability of theGDPR and the Swiss DPA: These privacy policy servesboth to provide information pursuant to the Swiss Federal Act on DataProtection (FADP) and the General Data Protection Regulation (GDPR). For thisreason, we ask you to note that due to the broader spatial application and comprehensibility,the terms used in the GDPR are applied. In particular, instead of the termsused in the Swiss FADP such as "processing" of "personaldata", "predominant interest", and "particularly sensitivepersonal data", the terms used in the GDPR, namely "processing"of "personal data", as well as "legitimate interest" and"special categories of data" are used. However, the legal meaning ofthese terms will continue to be determined according to the Swiss FADP withinits scope of application.

4. Security precautions

We take appropriate technical andorganisational measures in accordance with the legal requirements, taking intoaccount the state of the art, the costs of implementation and the nature,scope, context and purposes of processing as well as the risk of varyinglikelihood and severity for the rights and freedoms of natural persons, inorder to ensure a level of security appropriate to the risk.

The measures include, in particular,safeguarding the confidentiality, integrity and availability of data bycontrolling physical and electronic access to the data as well as access to,input, transmission, securing and separation of the data. In addition, we haveestablished procedures to ensure that data subjects' rights are respected, thatdata is erased, and that we are prepared to respond to data threats rapidly.Furthermore, we take the protection of personal data into account as early asthe development or selection of hardware, software and service providers, inaccordance with the principle of privacy by design and privacy by default.Securing online connections through TLS/SSLencryption technology (HTTPS): To protect the data of users transmitted via ouronline services from unauthorized access, we employ TLS/SSL encryptiontechnology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) arethe cornerstones of secure data transmission on the internet. Thesetechnologies encrypt the information that is transferred between the website orapp and the user's browser (or between two servers), thereby safeguarding thedata from unauthorized access. TLS, as the more advanced and secure version ofSSL, ensures that all data transmissions conform to the highest securitystandards. When a website is secured with an SSL/TLS certificate, this isindicated by the display of HTTPS in the URL. This serves as an indicator tousers that their data is being securely and encryptedly transmitted.

5. Transmission of personal data

In the course of processing personal data,it may happen that this data is transmitted to or disclosed to other entities,companies, legally independent organizational units, or individuals. Recipientsof this data may include service providers tasked with IT duties or providersof services and content that are integrated into a website. In such cases, weobserve the legal requirements and particularly conclude relevant contracts oragreements that serve to protect your data with the recipients of your data.

Data Transmission within the Group ofCompanies: Data transfer within the corporate group: We may transfer personaldata to other companies within our corporate group or grant them access to it.This data sharing is based on our legitimate business and economic interests.By this, we mean, for example, the improvement of business processes, ensuringefficient and effective internal communication, the optimal use of our humanand technological resources, as well as the ability to make informed business decisions.In certain cases, data sharing may also be necessary to fulfil our contractualobligations or may be based on the consent of the data subjects or a legal permission.

Data Transfer within the Organization: Wemay transfer personal data to other departments or units within ourorganisation or grant them access to it. If the data is shared foradministrative purposes, it is based on our legitimate business and economic interestsor occurs if it is necessary to fulfil our contractual obligations or if thedata subjects have given their consent or a legal permission exists.

6. International data transfers

7. Rights of data subjects

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

Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.

Right of withdrawal for consents: You have the right to revoke consents at any time.

Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.

Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you. Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.

Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.

Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Rights of the data subjects under the Swiss DPA: As the data subject, you have the followingrights in accordance with the provisions of the Swiss DPA:

Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the Swiss DPA and to ensure transparent data processing.

Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.

Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.

Right to object, deletion, and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed.

8. Provision of online services and web hosting

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

Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Log data (e.g. log files concerning logins or data retrieval or access times.). Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.).

Data subjects: Users (e.g. website visitors, users of online services). Business and contractual partners.

Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures; Content Delivery Network (CDN). Office and organisational procedures.

Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:
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Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Collection of Access Data and Log Files:
Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

Content-Delivery-Network:
We use a so-called "Content Delivery Network" (CDN). A CDN is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Amazon Web Services (AWS):
Servicesin the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg;
Legal Basis: Legitimate Interests (Article 6 (1)(f) GDPR);
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Website: https://aws.amazon.com/;
Privacy Policy: https://aws.amazon.com/privacy/;
Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Luxembourg).

Webflow:
Creation, management and hosting of websites, online forms and other web elements;
Service provider: Webflow, Inc., 398 11th St., Floor 2, 94103 San Francisco, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://webflow.com;
Privacy Policy: https://webflow.com/legal/eu-privacy-policy;
Data Processing Agreement: https://webflow.com/legal/dpa.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).

Cloudflare:
Content-Delivery-Network (CDN) - service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://www.cloudflare.com;
Privacy Policy: https://www.cloudflare.com/privacypolicy/;
Data Processing Agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).

Amazon CloudFront:
Content-Delivery-Network (CDN) - service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, 1855, Luxembourg; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);

Website: https://aws.amazon.com/cloudfront/;
Privacy Policy: https://aws.amazon.com/privacy/;
Data Processing Agreement: https://aws.amazon.com/compliance/gdpr-center/.
Basis for third-country transfers: EEA - Standard Contractual Clauses (Provided by the service provider), Switzerland - Adequacy decision (Luxembourg).

Google Cloud CDN:
Content-Delivery-Network (CDN) - service with whose help contents of our online services, inparticular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://cloud.google.com/cdn;
Privacy Policy: https://policies.google.com/privacy;
Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).
Further Information: https://cloud.google.com/privacy.

JSDelivr:
Content Delivery Network (CDN) that helps deliver media and files quickly and efficiently, especially under heavy load; Service provider: ProspectOne, Królewska 65A/1, 30-081, Kraków, Poland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://www.jsdelivr.com; Privacy
Policy: https://www.jsdelivr.com/terms/privacy-policy-jsdelivr-net.
Basis for third-country transfers: Switzerland - Adequacy decision (Poland).

9. Registration, login and user account

Users can create a user account. Within thescope of registration, the required mandatory information is communicated tothe users and processed for the purposes of providing the user account on thebasis of contractual fulfilment of obligations. The processed data includes inparticular the login information (name, password and an e-mail address).

Within the scope of using our registrationand login functions as well as the use of the user account, we store the IPaddress and the time of the respective user action. The storage is based on ourlegitimate interests, as well as the user's protection against misuse and otherunauthorized use. This data will not be passed on to third parties unless it isnecessary to pursue our claims or there is a legal obligation to do so.Users may be informed by e-mail ofinformation relevant to their user account, such as technical changes.

Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g.page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).

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

Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.

Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.

Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processingmethods, procedures and services used: Registration with a real name: Due to the nature of our community, we ask users to use our services only with their real names. This means that the use of pseudonyms is not permitted;

Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Users' profiles are public: The users' profiles are not publicly visible or accessible.

10. Contact and inquiry management

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

Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

Data subjects:
Communication partner (Recipients of e-mails, letters, etc.).
Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability. Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processingmethods, procedures and services used:

Contact form:
Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).

SendGrid:
Email sending and communication platform for transactional and marketing emails;
Service provider: Twilio Irland Limited, 25 – 28 North Wall Quay, North Wall, Dublin 1, D01 H104, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://sendgrid.com;
Privacy Policy: https://www.twilio.com/legal/privacy;
Data Processing Agreement: https://www.twilio.com/legal/data-protection-addendum.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).

11. Communication via messenger

We use messenger services for communicationpurposes and therefore ask you to observe the following information regardingthe functionality of the messenger services, encryption, use of the metadata ofthe communication and your objection options.

You can also contact us by alternativemeans, e.g. telephone or e-mail. Please use the contact options provided to youor use the contact options provided within our online services.

In the case of encryption of content (i.e.the content of your message and attachments), we point out that thecommunication content (i.e. the content of the message and attachments) isencrypted end-to-end. This means that the content of the messages is notvisible, not even by the messenger service providers themselves. You shouldalways use a current version of the messenger service with activatedencryption, so that the encryption of the message contents is guaranteed.

However, we would like to point out to ourcommunication partners that although messenger service providers do not see thecontent, they can find out that and when communication partners communicatewith us and process technical information on the communication partner's deviceused and, depending on the settings of their device, also location information(so-called metadata).

Information on Legal basis:
If we ask communicationpartners for permission before communicating with them via messenger services,the legal basis of our processing of their data is their consent. Otherwise, ifwe do not request consent and you contact us, for example, voluntarily, we usemessenger services in our dealings with our contractual partners and as part ofthe contract initiation process as a contractual measure and in the case ofother interested parties and communication partners on the basis of ourlegitimate interests in fast and efficient communication and meeting the needsof our communication partners for communication via messenger services. Wewould also like to point out that we do not transmit the contact data providedto us to the messenger service providers for the first time without yourconsent.
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Withdrawal, objection and deletion:
You can withdraw your consentor object to communication with us via messenger services at any time. In thecase of communication via messenger services, we delete the messages inaccordance with our general data retention policy (i.e. as described aboveafter the end of contractual relationships, archiving requirements, etc.) andotherwise as soon as we can assume that we have answered any informationprovided by the communication partners, if no reference to a previousconversation is to be expected and there are no legal obligations to store themessages to prevent their deletion.

Reservation of reference to other means of communication:
For your security, we kindly ask for your understanding that we may not respond to enquiries via messenger for specific reasons. This applies in situations where contract details require heightened confidentiality or a response via messenger does not meet formal requirements. In such cases, we recommend using more appropriate communication channels.

Processed data types:
Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).
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Data subjects:
Communication partner (Recipients of e-mails, letters, etc.). Purposes of processing: Communication. Direct marketing (e.g. by e-mail or postal). Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR). Further information on processing methods, procedures and services used:

WhatsApp:
Text messages, voice and video calls, sending images, videos and documents, group chat functionality, end-to-end encryption for enhanced security; Service provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://www.whatsapp.com/;
Privacy Policy: https://www.whatsapp.com/legal.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).

Discord:
Chat, audio and video broadcasting, instant messaging, and community management; Service provider: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://discordapp.com/;
Privacy Policy: https://discordapp.com/privacy.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).

12. Newsletter and electronic communications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration for the newsletter, these contents are decisive for the users' consent. Normally, providing your email address is sufficient to sign up for our newsletter. However, to offer you a personalised service, we may ask for your name for personal salutation in the newsletter or for additional information if necessary for the purpose of the newsletter.

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

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system.

Contents: Information about us, our services, promotions and offers.
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Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).

Data subjects: Communication partner (Recipients of e-mails, letters, etc.).

Purposes of processing: Direct marketing (e.g. by e-mail or postal).

Retention and deletion: 3 years - Contractual claims (AT) (Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 1478, 1480 of the Austrian Civil Code).). 10 years - Contractual claims (CH) (Data required to consider potential compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the statutory limitation period of ten years, unless a shorter period of 5 years is applicable, which is relevant in certain cases. This period begins at the end of the calendar year in which the claim arose (Articles 127 and 128 Swiss Code of Obligations (CO))). Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing methods, procedures and services used:

Measurement of opening rates and click rates:
The newsletters contain a so-called "web beacons", which is a pixel-sized file that is retrieved from our server, or the server of the dispatch service provider if one is used, when the newsletter is opened. In the course of this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of access are collected. This information is used to technically improve our newsletter based on technical data or target audiences and their reading behavior, which can be determined by their access locations (identifiable by IP address) or access times. This analysis also includes determining whether and when newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations serve to recognize the reading habits of our users and adjust our content to them or send different content according to the interests of our users. The measurement of opening and click rates, as well as the storage of the measurement results in user profiles and their further processing, are based on user consent. Unfortunately, it is not possible to revoke success measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In that case, stored profile information will be deleted; Legal Basis: Consent (Article 6 (1) (a) GDPR).

SendGrid:
Email sending and communication platform for transactional and marketing emails; Service provider: Twilio Irland Limited, 25 – 28 North Wall Quay, North Wall, Dublin 1, D01 H104, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);

Website: https://sendgrid.com;
Privacy Policy: https://www.twilio.com/legal/privacy;
Data Processing Agreement: https://www.twilio.com/legal/data-protection-addendum. Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).

13. Commercial communication by email, postal mail, fax or telephone

We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.The recipients have the right to withdrawtheir consent at any time or to object to the advertising communication at anytime.After revocation or objection, we store thedata required to prove the past authorization to contact or send up to threeyears from the end of the year of revocation or objection on the basis of ourlegitimate interests. The processing of this data is limited to the purpose ofa possible defense against claims. Based on the legitimate interest topermanently observe the revocation, respectively objection of the users, wefurther store the data necessary to avoid a renewed contact (e.g. depending onthe communication channel, the e-mail address, telephone number, name).

Processed data types:
Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Data subjects: Communication partner (Recipients of e-mails, letters, etc.). Purposes of processing: Direct marketing (e.g. by e-mail or postal); Marketing. Sales promotion. Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Legal Basis:Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processingmethods, procedures and services used:

SendGrid: Email sending and communication platform for transactional and marketing emails; Service provider: Twilio Irland Limited, 25 – 28 North Wall Quay, North Wall, Dublin 1, D01 H104, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://sendgrid.com;
Privacy Policy: https://www.twilio.com/legal/privacy;
Data Processing Agreement: https://www.twilio.com/legal/data-protection-addendum.
Basis for third-country transfers:
EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).

14. Web analysis, monitoring and optimization

Web analysis is used to evaluate thevisitor traffic on our website and may include the behaviour, interests ordemographic information of users, such as age or gender, as pseudonymousvalues. With the help of web analysis we can e.g. recognize, at which time ouronline services or their functions or contents are most frequently used orrequested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can alsouse test procedures, e.g. to test and optimize different versions of our onlineservices or their components.

Unless otherwise stated below, profiles,i.e. data aggregated for a usage process, can be created for these purposes andinformation can be stored in a browser or in a terminal device and read fromit. The information collected includes, in particular, websites visited andelements used there as well as technical information such as the browser used,the computer system used and information on usage times. If users have agreedto the collection of their location data from us or from the providers of theservices we use, location data may also be processed.

Unless otherwise stated below, profiles,that is data summarized for a usage process or user, may be created for thesepurposes and stored in a browser or terminal device (so-called"cookies") or similar processes may be used for the same purpose. Theinformation collected includes, in particular, websites visited and elementsused there as well as technical information such as the browser used, thecomputer system used and information on usage times. If users have consented tothe collection of their location data or profiles to us or to the providers ofthe services we use, these may also be processed, depending on the provider.

The IP addresses of the users are alsostored. However, we use any existing IP masking procedure (i.e.pseudonymisation by shortening the IP address) to protect the user. In general,within the framework of web analysis, A/B testing and optimisation, no userdata (such as e-mail addresses or names) is stored, but pseudonyms. This meansthat we, as well as the providers of the software used, do not know the actualidentity of the users, but only the information stored in their profiles forthe purposes of the respective processes.

Notes on legal bases:
If we ask users fortheir consent to use third-party providers, the legal basis for data processingis consent. Otherwise, user data will be processed on the basis of ourlegitimate interests (i.e. interest in efficient, economical andrecipient-friendly services). In this context, we would also like to draw yourattention to the information on the use of cookies in this privacy policy.

Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

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

Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (Creating user profiles).

Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention 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.).

Security measures: IP Masking (Pseudonymization of the IP address).
Legal Basis: Consent (Article 6 (1) (a) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processingmethods, procedures and services used:

fathom: Web analytics and reach measurement (no use of cookies, measurement is limited to our online sevices, use of data protection-friendly pseudonymisation procedures, see https://usefathom.com/data); Service provider: Conva Ventures Inc. BOX 37058 Millstream PO, Victoria, BC, V9B 0E8, Canada; Legal Basis: Consent (Article 6 (1) (a) GDPR);

Website: https://usefathom.com/;
Privacy Policy: https://usefathom.com/privacy.
Basis for third-country transfers: EEA - Adequacy decision (Canada), Switzerland - Adequacy decision (Canada).

15. Profiles in social networks (social media)

We maintain online presences within socialnetworks and process user data in this context in order to communicate with theusers active there or to offer information about us.

We would like to point out that user datamay be processed outside the European Union. This may entail risks for users,e.g. by making it more difficult to enforce users' rights.

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

For a detailed description of therespective processing operations and the opt-out options, please refer to therespective data protection declarations and information provided by theproviders of the respective networks.Also in the case of requests forinformation and the exercise of rights of data subjects, we point out thatthese can be most effectively pursued with the providers. Only the providershave access to the data of the users and can directly take appropriate measuresand provide information. If you still need help, please do not hesitate tocontact us.

Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).

Data subjects: Users (e.g. website visitors, users of online services). Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations. Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processingmethods, procedures and services used:

Instagram:
Social network, allows the sharing of photos and videos, commenting on and favouriting posts, messaging, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
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Website: https://www.instagram.com;
Privacy Policy: https://privacycenter.instagram.com/policy/.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland).

LinkedIn:
Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors for the purposes of creating „Page-Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from the users' profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn's privacy notices: https://www.linkedin.com/legal/privacy-policy We have concluded a special agreement with LinkedIn Irland, the 'Page Insights Joint Controller Addendum (the ‘Addendum’)' (https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and wherein LinkedIn has agreed to fulfill the rights of the affected parties (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of the users (in particular to access to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, particularly regarding the transmission 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 (Article 6 (1) (f) GDPR);
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Website: https://www.linkedin.com;
Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Adequacy decision (Ireland). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

X:
Social network;
Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal Basis: LegitimateInterests (Article 6 (1) (f) GDPR);
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Website: https://x.com;
Privacy Policy: https://x.com/privacy.
Basis for third-country transfers: Switzerland - Adequacy decision (Ireland).

Discord:
Chat, audio and video broadcasting, instant messaging, and community management;
Service provider: Discord, Inc., 444 De Haro St, Suite 200, San Francisco, California 94107, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);

Website: https://discordapp.com/;
Privacy Policy: https://discordapp.com/privacy.
Basis for third-country transfers: EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).

16. Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or city maps(hereinafter uniformly referred to as "Content").The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons")for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website.The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and usability.
Detention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention 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) GDPR). Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:
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Integration of third-party software, scripts or frameworks: We incorporate into our online services software which we retrieve from servers of other providers (e.g. function libraries which we use for the purpose of displaying or user-friendliness of our online services). The respective providers collect the user's IP address and can process it for the purposes of transferring the software to the user's browser as well as for security purposes and for the evaluation and optimisation of their services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). Google Fonts (Provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online services; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
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Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google. Google Hosted Libraries: Google Hosted Libraries is a globally available Content Delivery Network (CDN)for the most commonly used open-source JavaScript libraries. These are provided to supply web libraries that optimise website loading times, reduce bandwidth usage, and enhance performance through the use of shared, public resources; Service provider: Google Ireland Limited, GordonHouse, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);

Website: https://developers.google.com/speed/libraries/;
Privacy Policy: https://policies.google.com/privacy.
Basis for third-country transfers: Switzerland - Adequacy decision (Ireland).

Uploadcare: We utilize Uploadcare, a third-party service provider, to securely store and manage images uploaded to our platform. By using our service and uploading images, you acknowledge that these images will be transmitted to and stored on Uploadcare's servers. Uploadcare adheres to strict data protection standards and implements industry-best security practices to safeguard your uploaded content. For more information on how Uploadcare handles data, please refer to their privacy policy at https://uploadcare.com/about/privacy-policy/.

17. Changes and updates

We kindly ask you to inform yourselfregularly about the contents of our data protection declaration. We will adjustthe privacy policy as changes in our data processing practices make thisnecessary. We will inform you as soon as the changes require your cooperation(e.g. consent) or other individual notification.If we provide addresses and contactinformation of companies and organizations in this privacy policy, we ask youto note that addresses may change over time and to verify the informationbefore contacting us.

18. Terminology and definitions

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

Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.

Content Delivery Network (CDN):
A "Content Delivery Network" (CDN) is a service with whose help contents of our online services, in particular large media files, such as graphics or scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.

Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.

Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.

Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.

Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.

Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these 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, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.

Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings

Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics , pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.