Privacy Policy
(Information on Data Protection regarding our data processing according to Articles 12, 13, 14, and 21 of the General Data Protection Regulation)
We, gyde GmbH (hereinafter “gyde” or “we”), are pleased about your visit to our website https://www.gyde.io (hereinafter “website”) and your use of our Gyde platform via the mobile application (hereinafter “app” or “app application”) or web application (hereinafter “web app” or “app application”) under app.gyde.io (hereinafter, if website-related content is captured, also “website”) and your interest in our company. The protection of your personal data is an important concern for us. Below we inform you in accordance with Articles 12, 13, 14, and 21 of the General Data Protection Regulation (GDPR) about how we handle your personal data when using our website and app applications and when providing the services offered on the website and the app applications.
Personal data are specific pieces of information concerning personal or factual circumstances of a particular or identifiable natural person. This includes, for example, information such as the name, address, telephone number, and date of birth, but also the IP address.
A. General Information
I) Responsible party
gyde GmbH
Rotebühlstraße 50
70178 Stuttgart
Phone: (+49) 01575 5525175
Email: info@gyde.io
We are not legally obliged to appoint a data protection officer.
II) Data protection officer
rsdatenschutz
Bismarckstraße 2
71634 Ludwigsburg
Email: info@rsdatenschutz.de
B. Use of our website: Purposes and legal bases of data processing
I) Informational use of the website
You can visit our website without providing any information about yourself. If you only use our website informationally, i.e., if you do not register via the provided Google Docs form, do not write an email, or otherwise transmit information about yourself, we do not process any personal data, except for the data that your browser transmits to enable your visit to the website as well as information transmitted to us in the context of cookies used.
1. Technical provision of the website
a) Log files/Provision of the website
For the purpose of the technical provision of the website, our system (i.e., the web server) automatically collects information from your browser upon each access to the website. The temporary storage of your IP address by our system is necessary to enable the delivery of the website to your computer. For this purpose, the user's IP address must necessarily be stored for the duration of the session.
The storage of the IP address in log files occurs to ensure the functionality of our website. We also use this data to optimize the website and ensure the security of our information systems (e.g., attack detection).
The following information is collected:
- IP address and port;
- Browser type/version (e.g., Firefox 59.0.2 (64 Bit));
- Browser language (e.g., German);
- Operating system used (e.g., Windows 10);
- Inner resolution of the browser window;
- Screen resolution;
- Javascript activation;
- Cookies on/off;
- Stored cookie contents;
- Time of access;
- The previous website from which you came to us.
Furthermore, we use cookies to provide you with certain technical functions of our website. Some functions of our website cannot be offered without the use of cookies. Detailed information about the cookies can be found in the consent management.
We process your personal data for the technical provision of our website to safeguard our legitimate interests in accordance with Article 6 (1) f) GDPR, to be able to technically provide you with the website. Our legitimate interest lies in providing you with an appealing, technically working, and user-friendly website, as well as taking measures to protect our website from cyber risks and preventing our website from posing cyber risks to third parties.
b) Consent management
On our website, we use a consent manager. With the help of the consent manager, we obtain your consent for certain data processing activities that require consent (e.g., analysis, tracking, etc.). By using the consent manager, we can inform you about the individual cookies and tools we use. You can use the consent manager to choose which cookies and tools you want to categorically allow or reject. In addition, the consent manager also provides an overview of the cookies used and the possibility to change or revoke your consents. This enables you to make an informed decision about the sharing of your data and us a data protection-compliant, transparent, and documented use of cookies and tools.
The consent manager processes your personal data to record your decision regarding the approval of cookies and tools and to store it for a subsequent visit to our website. This includes, among other things, the corresponding cookie with your (consent) decision as well as other usage data, such as IP address, domain names, time of request, server data (including data transfer types, server status, etc.), country, browser, and operating system.
We process your personal data for the technical provision of the consent manager based on the following legal bases:
- for the use of cookie management to fulfill a legal obligation we are subject to as the responsible party according to Article 6 (1) c) GDPR. The legal obligation lies in informing you about cookies we use and obtaining and documenting your consent to data processing; and
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR, to be able to technically provide you with the cookie management. Our legitimate interest lies in being able to offer you an appealing, technically functioning, and user-friendly cookie management, as well as taking measures to protect the cookie management from cyber risks and preventing cyber risks to third parties arising from the cookie management.
2. Analysis and Tracking
For the purpose of analyzing and tracking the use of our website, we or the service providers working for us use cookies that enable an evaluation of your browsing behavior. This allows us to improve the quality of our website and its content. We learn how the website is used and can continuously optimize our offerings. Detailed information about the cookies and tools we use, their purposes, and functions, the processed data, data recipients, the location of processing, or the transfer to so-called third countries (outside the EU/EEA), as well as the storage durations can be obtained through the consent manager.
We particularly rely on the following third-party tools:
- Hubspot
- Google Forms
- Microsoft Forms
- Youtube (for videos)
- Calendly
- Google Analytics
- LinkedIn Insight Tag / Ad Conversion Tracking
- Google Ads / Ad Conversion Tracking
a) Google Ads / Ad Conversion Tracking
We use the online advertising program "Google AdWords/Google Ads" (hereinafter collectively "Adwords") and as part of Google AdWords the conversion tracking and remarketing. The Adwords and the aforementioned functions include analysis and tracking services of Google Inc. (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). When you click on an advertisement displayed by Google, a cookie for conversion tracking is placed on your computer. These cookies expire after 30 days, do not contain personal data, and therefore do not serve for personal identification. If you visit certain web pages before our website and the cookie has not expired, Google and we can recognize that you clicked on the ad and were redirected to that page. Each Google AdWords customer receives a different cookie. Thus, there is no possibility for cookies to be tracked across the websites of AdWords customers. The information obtained through the conversion cookie serves to create conversion statistics for AdWords customers who have opted for conversion tracking. Hereby, customers are informed about the total number of users who clicked on their advertisement, were redirected to a page marked with a conversion tracking tag, and there purchased a product or signed up for a newsletter. However, they do not receive any information that would allow personal identification of the users. The remarketing function, in turn, serves to re-engage users on other websites or other content that, for example, previously visited our websites. Through the remarketing cookie, Google recognizes the user on other websites as a former visitor of our website and can thus display optimized advertisements to the user. If you do not wish to participate in tracking, you can oppose this use by preventing the installation of cookies through a corresponding setting of your browser software (deactivation option). You will not be included in the conversion tracking statistics. Further information, as well as Google’s privacy policy, can be found at: http://www.google.com/policies/
technologies/ads
http://www.google.de/policies/privacy/
We process your personal and non-personal data for analysis on our website based on the following legal basis:
- your consent according to § 25 para. 1 TDDDG regarding the initial storage and retrieval of data as well as;
- your consent according to Article 6 (1) lit. a GDPR for further data processing (e.g., tracking).
You can revoke a consent you have given at any time in the future by reopening the consent manager on any page of our website and removing the tick you have set for consent within the respective category and then confirming the setting.
b) Google Analytics
On our website, we use Google Analytics, a web analysis service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies. The information generated by the cookie about your use of our website is usually transmitted to a server of Google in the USA and stored there. On our website, we use Google Analytics 4. In Google Analytics 4, IP addresses are not logged or stored, making IP anonymization unnecessary. Direct personal references can thus be excluded. On our behalf, Google will use this information to evaluate your use of the website, compile reports on website activities, and provide further services related to website usage and internet use to the website operator. The IP address transmitted by your browser within the framework of Google Analytics will not be merged with other data from Google. Within Google Analytics, we use, among others, the feature "Google Signals" to understand your user behavior and optimize our website, which collects data particularly regarding your internet user behavior. This includes, among other things, the browser you are using, the device used, and information about which device buyers are more likely to tend to a purchase. However, this data is provided to us by Google only in aggregated and already evaluated form, i.e., aggregated and thereby anonymized. A reference to individual datasets or tracking back to individual users is not possible for us.
We process your personal and non-personal data for analysis on our website based on the following legal basis:
- your consent according to § 25 para. 1 TDDDG regarding the initial storage and retrieval of data as well as;
- your consent according to Article 6 (1) lit. a GDPR for further data processing (e.g., analysis).
You can revoke a consent you have given at any time in the future by
- preventing the storage of cookies through a corresponding setting of your browser software; however, we would like to point out that in this case you may not be able to fully utilize all features of our website;
- downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de or
- reopening the consent manager on any page of our website and removing the tick you set for consent within the respective category and then confirming the setting. Further information regarding the terms of use and data protection of or at Google Analytics can be found at http://www.google.com/
analytics/terms/de.html or at https://www.google.de/intl/de/policies/
c) LinkedIn Insight Tag / Ad Conversion Tracking
Our website uses the conversion tool "LinkedIn Insight Tag" from LinkedIn Ireland Unlimited Company. This tool creates a cookie in your web browser that enables the collection of data such as IP address, device and browser characteristics, and page events (e.g., page views). This data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days. LinkedIn does not share any personal data with us but provides anonymized reports on the website audience and advertisement performance. Additionally, LinkedIn offers the option of retargeting through the Insight Tag. We can display targeted advertising outside our website using this data without identifying you as a website visitor. For more information on data protection at LinkedIn, please refer to the LinkedIn privacy policy and the LinkedIn cookie policy. LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To deactivate the Insight Tag on our website (“opt-out”), adjust your consent in the consent manager by reopening it on any page of our website. We process your personal and non-personal data for analysis on our website based on the following legal basis:
- your consent according to § 25 para. 1 TDDDG regarding the initial storage and retrieval of data as well as;
- your consent according to Article 6 (1) lit. a GDPR for further data processing (e.g., tracking).
You may revoke a consent you have given at any time for the future by reopening the consent manager and removing the tick you have set for consent under the respective category and then confirming the setting.
II) Active use of the website
1. Contact inquiries
If you have questions about our website, the services we offer, or otherwise wish to contact us, you can reach us directly at the contact details provided in section A. I).
To process and respond to your inquiries, we process the personal data you provide us in this context. This includes, in any case, your name and your email address to respond to you, as well as any other information you send us in the course of your message.
We process your personal data to respond to contact inquiries based on the following legal basis:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR; our legitimate interest lies in appropriately answering customer inquiries;
- if the inquiry aims at concluding a contract, the additional legal basis is Article 6 (1) b) GDPR;
- if the inquiry aims at asserting your rights as a data subject, the additional legal basis is Article 6 (1) c) GDPR, as the processing of your data is necessary to fulfill legal obligations.
In addition to the contact method mentioned above, there is also the possibility to contact us via the chat functions of YouTube and LinkedIn, HubSpot, Google Forms, Microsoft Forms, and Calendly. Further information regarding data collection concerning YouTube, LinkedIn, Google Forms, Microsoft Forms, and Calendly can be found in section J. “Data Processing during Social Media Use” of this privacy policy.
2. Registration for gyde courses
You can register on our website to sign up for our training courses. In these cases, you must provide personal data in an input mask and transmit it to us.
You must provide the following data:
- First and last name
- Email address
- Position in and name of the company for which the registration is made, or indication that one is registering oneself
- If the registration is for a company: number of persons to be registered
- Course title for which registration should occur
At the time of sending the registration, the following data will also be stored:
- The user's IP address
- Mobile device yes/no
- Date and time of registration
We process your data for registration for a course to fulfill a contract or to carry out pre-contractual measures according to Article 6 (1) b) GDPR.
3. Business analysis and market research
To operate our business economically, to recognize market trends, and the needs of contract partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata, whereby the affected persons include contract partners, interested parties, customers, visitors, and users of our services and website.
The analyses are conducted for the purpose of economic evaluations, marketing, and market research. In this context, we may account for the profiles of registered users with information, e.g., regarding the services they have used. The analyses serve to increase user-friendliness, optimize our offerings, and ensure economic efficiency. The analysis data solely serves us and will not be shared with third parties. A disclosure of analytical results occurs only under full anonymization through data aggregation.
We process your personal data for this purpose based on the following legal basis:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR;
- if provided for in individual cases, based on your consent according to Article 6 (1) a) GDPR.
4. Newsletter and promotional emails
With your consent, we use your data for advertising purposes, such as sending our newsletter, conducting promotional surveys, sending product information, inviting you to events and training that may interest you, follow-ups, status updates, birthday mailings, market research, and other marketing and promotional activities. We collect mandatory information such as your email address, but also information that you voluntarily provide to us. We use the voluntary information to continuously improve our customer relationship.
If we receive your email address in connection with the conclusion of a contract and you have not objected, we reserve the right to regularly send you offers for similar services from our offering by email. You can object to this use of your email address at any time by sending a message to the contact details provided in section A. I) or via a designated link in the promotional email or other opt-out methods described in the respective email, without incurring any costs other than the transmission costs according to the basic tariffs.
We process your data for sending newsletters and promotional emails on the following legal bases:
- if you have granted your consent according to Article 6 (1) a) GDPR;
- if you provided your email address to us in connection with the purchase of goods or services, to safeguard our legitimate interests according to Article 6 (1) f) GDPR in conjunction with § 7 (3) UWG; our legitimate interest is based on our economic interests in conducting advertising measures and targeted advertising.
5. Analysis of the response to promotional emails
With your consent, we also analyze with the help of our service provider HubSpot when and how you open and respond to our newsletters and promotional emails. Usually, the following data is stored:
- Email address of the user
- Send status of the receiving mail server
- Delivery status of the email
- Time at which the email was opened
- Clicks on links in the email and their time
The evaluation and analysis of this data help us to avoid sending you random advertising. Rather, we send you advertisements that match your areas of interest. This means, for example, we also compare which of our newsletters and promotional emails you open to avoid sending unnecessary emails to you. Additionally, we want to provide you with information that is relevant to you. By tracking open and click rates, we can better recognize which content is interesting for you. You can view the HubSpot privacy policy here: https://legal.hubspot.com/de/privacy-policy.
The processing of the data for the analysis of the response to newsletters and promotional emails occurs if you have granted your consent according to Article 6 (1) a) GDPR.
6. Enforcement of rights
We also process your personal data to assert our rights and enforce our legal claims. We also process your personal data to defend against legal claims. Finally, we process your personal data as far as necessary to prevent or pursue criminal offenses.
We process your personal data for this purpose based on the following legal basis:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR, as far as we assert legal claims, defend ourselves in legal disputes, or prevent or clarify criminal acts.
7. Compliance with legal obligations
We also process your personal data to fulfill other legal obligations. These may arise in connection with the handling of registrations or business communications. This includes, in particular, commercial, trade, or tax law retention periods.
We process your personal data based on the following legal basis:
- to fulfill a legal obligation that we are subject to according to Article 6 (1) c) GDPR in conjunction with commercial, trade, or tax law, as far as we are required to record and store your data.
C. Use of our training services: Purposes and legal bases of data processing
We process your personal data within the framework of our training services. The data we process from you is either provided by your employer if they registered you for one of our courses or directly from you if you registered yourself or made the corresponding data available in our app applications and group coaching sessions.
1. App applications/Gyde platform
In the app applications, learning content on leadership topics is made available in the form of microlearning units. In addition to simple text content, small quizzes and reflection tasks that can be answered through multiple-choice or text inputs are offered in the app applications. The goal of the app applications is to convey relevant learning content in a short time, to reinforce what has been learned through tasks, and to transfer reflection tasks into daily life. The data we collect from you is necessary to achieve the intended coaching goal and to continuously improve the services of rho data.
For this purpose, we particularly process the following data in the app applications:
- Email address of the user
- If login is via third-party providers: Token from Google, Apple, etc.
- Master data of the user
- First and last name of the user
- Company where the user is employed
- Role in the company
- Number of employees in the company or the respective area of work of the user
- Duration in the app application
- Number and time of completed units
- Time points of use
- Approximate location (when using the app)
- Diagnostic data
- Multiple choice responses or free text entries (possibly also special personal data according to Article 9 (1) GDPR, if voluntarily provided)
2. Virtual group coachings
Group coachings are offered at regular intervals (e.g., every 2 weeks) as part of the program. Here, the user participates in a video conference together with executives from other companies and a coach commissioned by rho data. During this group coaching, the topics learned in the app application are discussed and specific situations from the users' everyday lives are reflected upon. The goal of the group coachings is to reinforce the content learned in the app application and transfer it into daily life, as well as to find solutions to concrete challenging situations through mutual exchange and consulting from the coaches.
During the group coachings, the coach may take notes on the user's situation. These can be used by the coach to improve the quality of the coaching and by rho data to improve the overall quality of the services offered.
The data processed in this context cannot be generally determined. The resulting data depends individually on the answers given by the users in the app application, the statements of the users in the coaching sessions, and the respective evaluations or notes of the coach. This may also involve special personal data within the meaning of Article 9 (1) GDPR.
The virtual group coachings are conducted via Google Meet. rho data has no influence on the data processing by Google Meet. Each user enters into an independent usage relationship with Google when using Zoom. Further information regarding data processing by Google can be found at https://support.google.com/
meet/answer/9852160, https://cloud.google.com/privacy, and https://cloud.google.com/privacy/gdpr.
3. Legal basis for processing
We process your personal data on the basis of the following legal basis:
- If we have received your data from your employer for the purpose of pre-registration, we process the data provided like name and email address based on your consent granted to your employer according to Article 6 (1) a) GDPR. If you have registered yourself for our course and are our contracting partner, we process the data you provide to fulfill or initiate a contract with you according to Article 6 (1) b) GDPR.
- Regarding the information you provided in the app application and in the coaching sessions, we process your data based on your consent according to Article 6 (1) a) GDPR or Article 9 (2) a) GDPR.
D. Links
Some sections of our website include links to third-party websites. These websites are subject to their own data protection principles. We are not responsible for their operation, including data handling. If you send information to or via such third-party pages, you should check the privacy policies of these pages before providing any information that can be associated with you.
E. Categories of recipients
Initially, only our employees have knowledge of your personal data.
Your data will generally only be passed on to third parties to the extent that this is legally permitted or required or as far as you have granted your consent. We also share your data with the service providers we use as necessary to provide our services. We limit the transfer of data to what is necessary to provide our services to you. In some cases, our service providers receive your data as processors and are then strictly bound by our instructions in handling your data. In other cases, the recipients act independently with your data that we transmit to them.
Below, we name the categories of recipients of your data:
- Collection agencies and legal advisors in asserting our claims,
- public authorities and institutions, as far as we are legally obliged to,
- Payment service providers and banks, to collect outstanding payments from accounts or to refund amounts,
- Agencies, printing companies, and letter shops that assist us in conducting trainings, advertising measures, sweepstakes, etc.,
- IT service providers for the administration and hosting of our websites and services.
F. Transfer to third countries
In the context of using cookies and similar applications, we transmit your IP address or its truncated version as well as possibly other data to countries outside the European Union. The transfer of data is based on the standard contractual clauses designed and provided by the European Commission, which we have concluded with the respective providers.
If service providers are used in third countries and we can influence this, they are additionally required to comply with the level of data protection in Europe through the agreement of the EU standard contractual clauses in addition to written instructions. Alternatively, we transmit the data based on an adequacy decision of the EU Commission.
Furthermore, we do not transfer your personal data to countries outside the EU or the EEA or to international organizations.
G. Duration of storage
I) Informational use of the website
When using our website purely for informational purposes, we store your personal data on our servers solely for the duration of your visit to our website. After you leave our website, your personal data will be deleted within 7 days. Cookies installed by us are usually also deleted after you leave our website.
Some cookies are, however, stored longer; you will receive further information on the storage durations of the cookies and tools we use through the consent manager. Additionally, you have the option to delete installed cookies at any time.
II) Active use of the website
When actively using our website, we store your personal data initially for the duration of responding to your request or for the duration of our business relationship. This also includes the potential future and the actual initiation of a contract (pre-contractual legal relationship) and the processing of a contract.
We process your data for the duration of your receiving our promotional emails until you object to sending them or revoke your consent.
Additionally, we store your personal data until the period of limitation for any legal claims arising from the relationship with you, in order to use them as evidence if necessary. The limitation period generally amounts to between 1 and 3 years but can also be up to 30 years.
Upon the expiration of the limitation period, we delete your personal data unless a legal retention obligation exists, for example, from the Commercial Code (§§ 238, 257 para. 4 HGB) or from the Tax Code (§ 147 Abs. 3, 4 AO). These retention obligations can last from two to ten years. For this period, the data will only be processed for the purpose of a review by the tax authorities.
III) Use of app applications and data processing during virtual group coachings
As long as you are using our app applications or participating in virtual group coachings, we will store the personal data collected during this for the duration of the respective training program and will be viewable by the user until the user requests deletion or the contractual relationship ends. Once the users no longer have access to the platform, the data will be deleted unless there are compelling reasons (e.g., legal retention obligations, enforcement of rights, etc.) to the contrary.
Your data may be aggregated by us so that a reference to your person is no longer possible. These aggregated data can then be continuously evaluated and permanently used to optimize our services. A transfer of the data to third parties occurs, if at all, only in an anonymized aggregated form.
H. Scope of your obligations to provide data
In principle, you are not obliged to provide us with your personal data. However, if you do not do so, it may be that we cannot provide you with the website or app applications with all technical functionalities, cannot answer your inquiries to us, and cannot enter into a contract with you or provide training services.
I. Profiling / Automated decision-making
In the context of analyzing and evaluating your reaction to our promotional emails, your data are partially processed automatically with the aim of assessing certain personal aspects (profiling). This is done to inform and advise you purposefully about products and services. This enables communication and advertising tailored to your needs, including market and opinion research.
Moreover, we do not conduct profiling and do not use any purely automated decision-making procedures according to Article 22 GDPR. If we should implement further procedures in individual cases in the future, we will inform you separately about this.
J. Data processing during social media use
To represent our company and communicate directly with you, we use social media platforms from providers such as LinkedIn, YouTube, HubSpot, Calendly, and Co. (“providers”), through which we maintain our presence (e.g., within the framework of company and employee profiles) and process your data.
I) Joint responsibility
If data is collected on our website, which is processed and used for joint purposes by both the provider and us (e.g., within the framework of analysis or advertising), there is joint responsibility of the operator and us. Often, this function cannot be deactivated by us. You can therefore address your concerns both to the respective provider and to us. We currently use the following providers:
- LinkedIn (including LinkedIn Sales Navigator) of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (address of the German branch: LinkedIn Germany GmbH, Sendlinger Str. 12, 80333 Munich)
- YouTube Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (address of the German branch: Google Germany GmbH, ABC-Straße 19, 20354 Hamburg),
- HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA
- Calendly LLC, 271 17th St NW Ste 1000, Atlanta, GA 30363, USA
Below, you will find links to the respective providers' privacy policies and information:
- LinkedIn: https://de.linkedin.com/legal/privacy-policy
- Google (YouTube): https://policies.google.com/privacy
- Microsoft: https://privacy.microsoft.com/en-us/privacystatement
- HubSpot: https://legal.hubspot.com/de/privacy-policy
- Calendly: https://calendly.com/privacy
II) Data protection officers of the providers
In addition to us, you may also contact the following data protection officers of the respective providers:
- LinkedIn: https://www.linkedin.com/help/
linkedin/ask/TSO-DPO
- Google (YouTube): https://support.google.com/policies/
contact/general_privacy_form
- HubSpot: privacy@hustle.co
- Microsoft: https://www.microsoft.com/de-de/concern/privacy
- Calendly: privacy@calendly.com
III) Purposes and legal bases of data processing
1. Informational use of our appearance
a) Provision of the appearance
For the purpose of technical provision of our Social Media appearance, the web server automatically collects information from your browser upon each access to the website. You can visit our appearance without providing any information about yourself. If you only use our appearance informationally, i.e., if you do not register or do not otherwise transmit information about yourself, we do not process any personal data, except for the data collected by the provider as part of its platform and the cookies it employs and possibly transmits to us.
We or the provider process your personal data for the technical provision of our website based on the following legal bases:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR, in order to technically provide you with the presence. Our legitimate interest lies in being able to provide you with an appealing, technically functioning, and user-friendly presence as well as taking measures to protect our presence from cyber risks and preventing our presence from posing cyber risks to third parties.
b) Analysis and tracking
For the purpose of analyzing and tracking the use of its social media platform as well as our presence, the provider uses cookies that enable an evaluation of your browsing behavior. This allows for the quality of the platform and presence and their content to improve. We learn how the platform and the presence are used and can continuously optimize our offerings.
However, we have no influence on the data collected and data processing operations, nor do we know the full extent of data collection, the exact purposes of processing, or the storage periods. We also do not have any information regarding the deletion of the data collected by the platform operator.
Web analysis is the collection, aggregation, and evaluation of data regarding the behavior of visitors to websites. A web analysis service collects, among other things, data about which website a person has come from (so-called referrer), which subpages of the website are accessed, or how often and for what duration a subpage is viewed. Web analysis is regularly used to optimize a website and for cost-benefit analysis of online advertising. It may also happen that the information obtained in the course of analyzing and tracking our presence is combined with your other data collected in the context of using the presence and the platform. If you register on the platform, the operator may link data regarding your platform activities with your personal information (e.g., name/email address) based on consent given, thus personalizing data collection and informing you individually and purposefully about the topics you prefer.
With regard to statistics that the platform operator provides us, we can only influence them to a limited extent and cannot switch them off. However, we ensure that no additional optional statistics are provided to us.
We process your personal data on the basis of the following legal basis:
- your consent according to Article 6 (1) a) GDPR, which you have given to the provider when registering for the respective social media platform.
2. Active use of the presence
In addition to the purely informational use of our presence, you can also actively use our presence to contact us. In addition to the processing of your personal data for pure informational use described above, we also process further personal data from you, which we need to process your request. This applies also if we actively use the presence, e.g., for proactive outreach or the initiation of business contacts with you.
a) Sharing and publishing and interacting with posts, reviews, photos, etc.
You can comment, share, or otherwise interact (like, recommend, review, etc.) with posts, photos, videos, etc., created by us on the provider's platform and our presence. If this is a function of the provider's platform, we may also share your content on our presence and communicate with you through the platform. Public messages, etc., may be published by the provider, but we will never use or process them for any other purposes.
In the case of reviews, we may publish a statement (e.g., to clarify a problem, goodwill actions, etc.) on your communication and invite you to further contact. In doing so, processing of personal data that you voluntarily publish in the review may occur.
In any case, we reserve the right to delete content if necessary.
We process your personal data on the following legal basis:
- To safeguard our legitimate interests according to Article 6 (1) S. 1 f) GDPR. The data processing serves our public relations and communication interests.
b) User inquiries
To process your inquiries to us, e.g., through contact forms, a chat, or our email address, to target them and provide you with the requested information, we process the personal data you provide in this context. This includes your contact details, to provide you with a response or to ask necessary follow-up questions, as well as any other information you transmit to us in this context.
If you submit an inquiry via the platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the response required. You always have the option to send us confidential inquiries to the addresses listed in the imprint or this privacy policy. Our replies to you may occur electronically, by phone, or by post, depending on the subject of the inquiry, availability of your contact details, and appropriateness.
We process your personal data to respond to user inquiries, request materials, etc., based on the following legal bases:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR; our legitimate interest lies in appropriately responding or executing (customer) inquiries;
- if the inquiry aims at concluding a contract or pertains to the services to be provided, or relates in another manner to a contractual and/or business relationship between us and you, the additional legal basis is Article 6 (1) b) GDPR;
- with your consent in the context of using the chat, Article 6 (1) a) GDPR.
c) Enforcement of rights
We also process your personal data to assert our rights and enforce our legal claims. We also process your personal data to defend against legal claims. Finally, we process your personal data as far as necessary to prevent or pursue criminal offenses.
We process your personal data for this purpose based on the following legal basis:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR, to the extent that we assert legal claims or defend ourselves in legal disputes or prevent or clarify criminal acts.
d) Compliance with legal obligations
We also process your personal data on our social media presence to fulfill other legal obligations. These may arise, among other things, in connection with the processing of registrations or business communications. This includes, in particular, commercial, trade, or tax law retention periods. We process your personal data based on the following legal basis:
- to fulfill a legal obligation that we are subject to according to Article 6 (1) c) GDPR in conjunction with commercial, trade, or tax law, as far as we are required to record and store your data.
e) Transfer to third countries
In the context of social media use, your data may be transmitted to countries outside the European Union, including the USA. We have no influence on this. Further information can be found in the linked privacy policies of the platform operators.
f) Storage duration
When using our social media presence, the operator stores your personal data on its servers. Personal data and installed cookies are deleted by the operator in general. However, we do not know the exact storage and deletion periods, which can sometimes be obtained from the respective linked privacy policies.
g) Profiling / automated decision-making
There is a possibility that the operator of a social media platform processes your data partially automatically with the aim of assessing certain personal aspects (profiling). This may be done to inform and advise you purposefully about products and services. This allows tailored communication and advertising including market and opinion research.
K. Company sale/mergers, etc.
We process your personal data under certain circumstances to handle a (partial) company sale or a merger (or similar processes such as acquisition under liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire the assets, which may include your personal data, from us or if we conduct or intend to conduct a merger with another company, we may need to grant that company access to your personal data stored with us or transfer them for the purpose of examining and executing the company sale/merger (e.g., for determining the company value or business risks, to transfer data/assets, etc.).
We process your personal data based on the following legal basis:
- to safeguard our legitimate interests according to Article 6 (1) f) GDPR, to organize and conduct a planned company sale or merger.
L. Rights of the data subjects
If personal data is processed about you, you are a “data subject” within the meaning of the GDPR. You are entitled to the following rights as a data subject under the legal requirements, which you can assert against us or, within the framework of using a social media service, also against the operator. Please note that we do not have full influence over the data processing operations of the operator. Our options are significantly determined by the corporate policy of the respective operator. Your rights as a data subject are as follows:
- Right to information: You are entitled to request, under Article 15 GDPR, confirmation from us as to whether we are processing personal data concerning you. If this is the case, you are entitled, under Article 15 GDPR, to request information about this personal data as well as certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage duration, the origin of the data, the application of automated decision-making, and in the case of transfer to third countries, the appropriate guarantees) and a copy of your data.
- Right to rectification: In the event that personal data concerning you is (no longer) accurate or incomplete, you may request rectification and, if necessary, the completion of this data (Article 16 GDPR).
- Right to erasure or restriction of processing: If the legal requirements are met, you may request the erasure of your personal data (Article 17 GDPR) or the restriction of the processing of this data (Article 18 GDPR). However, the right to erasure under Articles 17 (1) and (2) GDPR does not exist, among other things, if the processing of personal data is necessary to comply with a legal obligation (Article 17 (3) lit. b GDPR).
- Right to object: For reasons relating to your particular situation, you may also object at any time to the processing of personal data concerning you by us (Article 21 GDPR). If the legal requirements are met, we will no longer process your personal data.
- Right to data portability: You have the right, under the conditions set out in Article 20 GDPR, to request that we provide you with the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format.
- Right to withdraw the data protection consent: You have the right to withdraw your consent at any time. The withdrawal is effective only for the future; that is, the lawfulness of the processing that was based on the consent prior to the withdrawal remains unaffected.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, a data subject (you) has the right to lodge a complaint with a supervisory authority – especially in the member state of your residence – if you believe that the processing of your personal data by us is in violation of the GDPR.
The supervisory authority responsible for us is:
The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart
Phone: 0711/61 55 41 – 0
Fax: 0711/61 55 41 – 15
Email: poststelle@lfdi.bwl.de
The social media platform operators and thus also the responsible supervisory authority are based outside the EU. Typically, this is the Irish data protection authority (Data Protection Commission, 21 Fitzwilliam Square South, Dublin2, D02RD28, Ireland). However, you can also address your complaints to the following German supervisory authorities. This is basically:
- LinkedIn: The Bavarian State Office for Data Protection Supervision, Promenade 18, 91522 Ansbach;
- Google (including YouTube): The Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str 22, 7th floor, 20459 Hamburg;
Your requests regarding the exercise of your rights should be addressed preferably in writing to the above addresses of the supervisory authorities or directly to us at the contact details provided in section A. I).
M. Right to object Article 21 GDPR
You have the right to object at any time to the processing of your data that occurs based on Article 6 (1) f GDPR (data processing on the basis of a balancing of interests) or Article 6 (1) e GDPR (data processing in the public interest) if there are reasons that arise from your specific situation. This also applies to any profiling based on this provision according to Article 4 No. 4 GDPR.
If you lodge an objection, your personal data will no longer be processed unless compelling legitimate grounds for the processing can be demonstrated, which override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims.
Your personal data may also be processed in certain cases to conduct direct advertising. If you do not wish to receive advertising, you have the right to object to this at any time; this also applies to profiling to the extent it is related to such direct advertising. This objection will be observed for the future.
Your data will no longer be processed for direct marketing purposes if you object to the processing for these purposes.
The objection can be made informally and should be addressed as far as possible to us at the contact details provided in section A. I) or to the contact details of the respective platform operator.
N. Changes
This privacy policy is a transparency document. We are obliged to update it when our data processing changes.
Last updated in July 2025