Privacy Policy

Privacy Policy

1. Data protection at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on data protection, please refer to our privacy policy set out below this text.

Data collection on our website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the controller” in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us. This may, for example, be data you enter into a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (for example internet browser, operating system or the time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given consent to data processing, you can withdraw that consent at any time with effect for the future. You also have the right, under certain circumstances, to request that the processing of your personal data be restricted. You furthermore have a right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the subject of data protection.

Analytics tools and third-party tools

When you visit this website, your browsing behaviour may be analysed statistically. This is done primarily using so-called analytics programs.

You can find detailed information about these analytics programs in the privacy policy below.

2. Hosting and content delivery networks (CDN)

We host the content of our website with the following provider:

Webflow

The provider is Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA (hereinafter Webflow). When you visit our website, Webflow records various log files including your IP addresses.

Webflow is a tool for creating and hosting websites. Webflow stores cookies or other recognition technologies that are necessary for displaying the page, for providing certain website functions and for ensuring security (necessary cookies).

For details, please refer to Webflow’s privacy policy: https://webflow.com/legal/eu-privacy-policy.

Webflow is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in presenting our website as reliably as possible. Where corresponding consent was requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (for example device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://webflow.com/legal/eu-privacy-policy.

The company holds a certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information on this from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000TT9jAAG&status=Active

Data processing on our behalf

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Cloudflare

We use the “Cloudflare” service. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).

Cloudflare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through Cloudflare’s network. This enables Cloudflare to analyse the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies to recognise internet users, which are however used solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our web offering as free of errors and as securely as possible (Art. 6(1)(f) GDPR).

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://www.cloudflare.com/privacypolicy/.

You can find further information on security and data protection at Cloudflare here: https://www.cloudflare.com/privacypolicy/.

Data processing on our behalf

3. General information and mandatory disclosures

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would point out that data transmission over the internet (for example when communicating by e-mail) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the controller

The controller for data processing on this website is:

smoxy GmbH

Horstweg 24

14059 Berlin

Phone: +49 (30) 555722960

E-mail: info@smoxy.eu

The controller is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (for example names, e-mail addresses and the like).

Storage period

Unless a more specific storage period is stated within this privacy policy, your personal data remains with us until the purpose for the data processing no longer applies. If you assert a justified request for deletion or withdraw consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (for example retention periods under tax or commercial law); in the latter case, deletion takes place once those grounds cease to apply.

General information on the legal bases for data processing on this website

Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR where special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of express consent to the transfer of personal data to third countries, data processing additionally takes place on the basis of Art. 49(1)(a) GDPR. Where you have consented to the storage of cookies or to access to information in your terminal device (for example via device fingerprinting), data processing additionally takes place on the basis of § 25(1) TTDSG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for carrying out pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. We furthermore process your data where it is required for compliance with a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also take place on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The legal bases relevant in each individual case are set out in the following paragraphs of this privacy policy.

Data protection officer

We have appointed a data protection officer.

Jens Paul

Carl-Schurz-Straße 21-23

66953 Pirmasens

E-mail: privacy@nemesisconsulting.de

Information on data transfer to third countries that are not secure under data protection law and on transfer to US companies that are not DPF-certified

Among other things, we use tools from companies based in third countries that are not secure under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in those countries. We would point out that in third countries that are not secure under data protection law, a level of data protection comparable to that of the EU cannot be guaranteed.

We would point out that the USA, as a secure third country, generally has a level of data protection comparable to that of the EU. A data transfer to the USA is therefore permissible if the recipient holds a certification under the “EU-US Data Privacy Framework” (DPF) or has suitable additional safeguards in place. Information on transfers to third countries, including the data recipients, can be found in this privacy policy.

Recipients of personal data

In the course of our business activities we work with various external parties. In some cases this also requires personal data to be transferred to these external parties. We only pass on personal data to external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (for example passing data to tax authorities), where we have a legitimate interest in the transfer pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits the transfer. Where processors are used, we pass on our customers’ personal data only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent already given at any time. The lawfulness of the data processing carried out up to the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in particular cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of infringements of the GDPR, data subjects have a right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged infringement. This right to complain exists without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do so. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored with us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened or is happening unlawfully, you can request the restriction of the data processing instead of deletion.
If we no longer need your personal data but you need it to exercise, defend or establish legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the establishment, exercise or defence of legal claims, or to protect the rights of another natural or legal person, or for reasons of an important public interest of the European Union or of a member state.

SSL / TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the padlock symbol in your browser bar.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to advertising e-mails

We hereby object to the use of contact details published under the obligation to provide a legal notice for the purpose of sending advertising and information material that has not been expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example by spam e-mails.

4. Data collection on this website

Cookies

Our web pages use so-called “cookies”. Cookies are small data packages and do no harm to your terminal device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are deleted automatically at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or until they are deleted automatically by your web browser.

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable certain services of third-party companies to be integrated within web pages (for example cookies for processing payment services).

Cookies have various functions. Numerous cookies are technically necessary, since certain website functions would not work without them (for example the shopping cart function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions you have requested (for example the shopping cart function) or to optimise the website (for example cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies was requested, processing takes place exclusively on the basis of that consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG); consent can be withdrawn at any time.

You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

You can find out which cookies and services are used on this website in this privacy policy.

Consent with Cookiebot

Our website uses the consent technology of Cookiebot to obtain your consent to the storage of certain cookies on your terminal device or to the use of certain technologies, and to document this in compliance with data protection law. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).

When you enter our website, a connection is established to Cookiebot’s servers in order to obtain your consent and other declarations regarding the use of cookies. Cookiebot then stores a cookie in your browser so that the consent given, or its withdrawal, can be attributed to you. The data collected in this way is stored until you ask us to delete it, delete the Cookiebot cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.

Cookiebot is used in order to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Data processing on our behalf

Enquiry by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your enquiry including all personal data arising from it (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry is connected with the performance of a contract or is necessary for carrying out pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) where this was requested; consent can be withdrawn at any time.

The data you send us via contact enquiries remains with us until you ask us to delete it, withdraw your consent to storage, or the purpose for storing the data no longer applies (for example after your request has been fully processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Eventbrite

On our website you have the option of booking tickets for various events. Tickets are booked via the Eventbrite ticket booking system. The provider is Eventbrite, Inc., Delaware, 155 5th Street, Floor 7, San Francisco, CA 94103, USA.

When you book a ticket with us, Eventbrite records all the data you provide during the booking (name, e-mail address and so on). In addition, your payment data, your IP address and further metadata (browser, operating system, version, terminal device) are recorded. You can view Eventbrite’s privacy policy here: https://www.eventbrite.de/support/articles/de/Troubleshooting/datenschutzrichtlinie-von-eventbrite?lg=de.

The data you enter remains with us until you ask us to delete it, withdraw your consent to storage, or the purpose for storing the data no longer applies. Mandatory statutory provisions – in particular retention periods – remain unaffected.

The legal basis for the data processing is Art. 6(1)(f) GDPR. The website operator has a legitimate interest in ticket booking being as straightforward as possible. Where corresponding consent was requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (for example device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://www.eventbrite.de/support/articles/de/Troubleshooting/datenschutzrichtlinie-von-eventbrite?lg=de.

Data processing on our behalf

Hubspot CRM

We use Hubspot CRM on this website. The provider is Hubspot Inc. 25 Street, Cambridge, MA 02141 USA (hereinafter Hubspot CRM).

Hubspot CRM enables us, among other things, to manage existing and potential customers as well as customer contacts. With the help of Hubspot CRM we are able to record, sort and analyse customer interactions by e-mail, social media or telephone across various channels. The personal data recorded in this way can be evaluated and used for communication with the potential customer or for marketing measures (for example newsletter mailings). Hubspot CRM furthermore enables us to record and analyse the user behaviour of our contacts on our website.

Hubspot CRM is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in customer management and customer communication being as efficient as possible. Where corresponding consent was requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (for example device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

For details, please refer to Hubspot’s privacy policy: https://legal.hubspot.com/de/privacy-policy.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://www.hubspot.de/data-privacy/privacy-shield.

Data processing on our behalf

5. Analytics tools and advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies into our website. Google Tag Manager itself does not create user profiles, does not store cookies and does not carry out any analyses of its own. It merely serves to manage and deliver the tools integrated through it. Google Tag Manager does, however, record your IP address, which may also be transferred to Google’s parent company in the United States.

Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the fast and straightforward integration and management of various tools on its website. Where corresponding consent was requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (for example device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

Google Analytics

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, time on page, operating systems used and the origin of the user. This data is attributed to the user’s respective terminal device. It is not attributed to a user ID.

In addition, Google Analytics allows us, among other things, to record your mouse and scroll movements and clicks. Google Analytics also uses various modelling approaches to supplement the recorded data sets and employs machine learning technologies in data analysis.

Google Analytics uses technologies that enable the user to be recognised for the purpose of analysing user behaviour (for example cookies or device fingerprinting). The information collected by Google about the use of this website is generally transferred to a Google server in the USA and stored there.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymisation

Google Analytics IP anonymisation is activated. As a result, your IP address is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transferred to the USA. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services relating to website use and internet use. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other Google data.

Browser plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on how user data is handled in Google Analytics in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Data processing on our behalf

We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Google Analytics e-commerce measurement

This website uses the “e-commerce measurement” function of Google Analytics. With the help of e-commerce measurement, the website operator can analyse the purchasing behaviour of website visitors in order to improve its online marketing campaigns. Information such as the orders placed, average order values, shipping costs and the time from viewing to purchasing a product is recorded. This data can be aggregated by Google under a transaction ID which is attributed to the respective user or their device.

Microsoft Advertising

The website operator uses Microsoft Advertising. Microsoft Advertising is an online advertising program of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

Microsoft Advertising enables us to display advertisements in the Bing search engine or on third-party websites when the user enters certain search terms in Bing (keyword targeting). Targeted advertisements can also be displayed on the basis of the user data available at Microsoft (for example location data and interests) (audience targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to our advertisements being displayed and how many advertisements led to corresponding clicks.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://learn.microsoft.com/de-de/compliance/regulatory/offering-eu-model-clauses.

Data processing on our behalf

Google Optimize

We have integrated Google Optimize into this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter Google Optimize).

Google Optimize enables us to optimise our website by carrying out tests (A/B testing) and personalisations of the website. For this purpose, Google Optimize processes the IP address of website visitors. The personal data collected may subsequently be processed by further analytics tools.

Google Optimize is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the optimal design of its online presence. Where corresponding consent was requested, processing takes place exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (for example for device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

For further details, please refer to the provider’s privacy policy at https://business.safety.google/adsprocessorterms/.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

Data processing on our behalf

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms in Google (keyword targeting). Targeted advertisements can also be displayed on the basis of the user data available at Google (for example location data and interests) (audience targeting). As the website operator, we can evaluate this data quantitatively, for example by analysing which search terms led to our advertisements being displayed and how many advertisements led to corresponding clicks.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

Google AdSense (non-personalised)

This website uses Google AdSense, a service for integrating advertisements. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use Google AdSense in “non-personalised” mode. In contrast to the personalised mode, the advertisements are therefore not based on your previous user behaviour and no user profile is created for you. Instead, so-called “contextual information” is used when selecting the advertising. The advertisements selected are then based, for example, on your location, the content of the website you are on, or your current search terms. You can find more on the differences between personalised and non-personalised targeting with Google AdSense at: https://support.google.com/adsense/answer/9007336.

Please note that cookies or comparable recognition technologies (for example device fingerprinting) may also be used when Google AdSense is used in non-personalised mode. According to Google, these are used to combat fraud and abuse.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/.

You can adjust your advertising settings yourself in your user account. To do so, click on the following link and log in: https://adssettings.google.com/authenticated.

You can find further information on Google’s advertising technologies here: https://policies.google.com/technologies/ads and https://www.google.de/intl/de/policies/privacy/.

Google Ads Remarketing

This website uses the functions of Google Ads Remarketing. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads Remarketing we can assign people who interact with our online offering to certain target groups in order to subsequently show them interest-based advertising in the Google advertising network (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Ads Remarketing can be linked to Google’s cross-device functions. In this way, interest-based, personalised advertising messages that have been adapted to you depending on your previous usage and browsing behaviour on one device (for example a mobile phone) can also be displayed on another of your devices (for example a tablet or PC).

If you have a Google account, you can object to personalised advertising at the following link: https://www.google.com/settings/ads/onweb/.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

Further information and the data protection provisions can be found in Google’s privacy policy at: https://policies.google.com/technologies/ads?hl=de.

Google conversion tracking

This website uses Google conversion tracking. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the help of Google conversion tracking, Google and we can recognise whether the user has carried out certain actions. For example, we can evaluate which buttons on our website were clicked how often and which products were viewed or purchased particularly frequently. This information serves to compile conversion statistics. We learn the total number of users who clicked on our advertisements and what actions they carried out. We do not receive any information by which we could personally identify the user. Google itself uses cookies or comparable recognition technologies for identification.

This service is used on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. Consent can be withdrawn at any time.

You can find more information on Google conversion tracking in Google’s data protection provisions: https://policies.google.com/privacy?hl=de.

LinkedIn Insight Tag

This website uses LinkedIn’s Insight Tag. The provider of this service is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data processing by the LinkedIn Insight Tag

With the help of the LinkedIn Insight Tag we receive information about the visitors to our website. If a website visitor is registered with LinkedIn, we can analyse, among other things, the professional key data (for example career level, company size, country, location, industry and job title) of our website visitors and thus better target our site to the respective audiences. Furthermore, with the help of LinkedIn Insight Tags we can measure whether the visitors to our web pages make a purchase or carry out another action (conversion measurement). Conversion measurement can also take place across devices (for example from PC to tablet). LinkedIn Insight Tag also offers a retargeting function with which we can display targeted advertising to visitors to our website outside the website, whereby according to LinkedIn no identification of the advertising recipient takes place.

LinkedIn itself also records so-called log files (URL, referrer URL, IP address, device and browser characteristics and the time of access). The IP addresses are truncated or (where they are used to reach LinkedIn members across devices) hashed (pseudonymised). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymised data is then deleted within 180 days.

The data collected by LinkedIn cannot be attributed to specific individuals by us as the website operator. LinkedIn will store the personal data of website visitors it collects on its servers in the USA and use it as part of its own advertising measures. For details, please refer to LinkedIn’s privacy policy at https://www.linkedin.com/legal/privacy-policy#choices-oblig.

Legal basis

Where consent has been obtained, the above-mentioned service is used exclusively on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG. Consent can be withdrawn at any time. Where no consent has been obtained, this service is used on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising measures including social media.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

Objection to the use of the LinkedIn Insight Tag

Object to the analysis of usage behaviour and to targeted advertising by LinkedIn at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

LinkedIn members can also control the use of their personal data for advertising purposes in their account settings. To avoid LinkedIn linking data collected on our website with your LinkedIn account, you must log out of your LinkedIn account before visiting our website.

Data processing on our behalf

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you consent to receiving the newsletter. No further data is collected, or only on a voluntary basis. For the handling of the newsletter we use newsletter service providers, which are described below.

Mailchimp with success measurement deactivated

This website uses the services of Mailchimp for sending newsletters. The provider is The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Mailchimp is a service with which, among other things, the sending of newsletters can be organised. If you enter data for the purpose of receiving the newsletter (for example an e-mail address), it is stored on Mailchimp’s servers in the USA. We have deactivated success measurement at Mailchimp, so that Mailchimp will not analyse your behaviour when opening our newsletters.

If you do not want your data to be transferred to Mailchimp, you must unsubscribe from the newsletter. For this purpose we provide a corresponding link in every newsletter message.

Data processing takes place on the basis of your consent (Art. 6(1)(a) GDPR). You can withdraw this consent at any time by unsubscribing from the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the withdrawal.

The data you have stored with us for the purpose of receiving the newsletter is stored by us or by the newsletter service provider until you unsubscribe from the newsletter and is deleted from the newsletter distribution list after you unsubscribe. Data stored with us for other purposes remains unaffected by this.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored in a blacklist by us or the newsletter service provider, where this is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the statutory requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You may object to the storage insofar as your interests outweigh our legitimate interest.

For further details, please refer to Mailchimp’s data protection provisions at: https://mailchimp.com/legal/terms/.

Data processing on our behalf

7. E-commerce and payment providers

Processing of customer and contract data

We collect, process and use personal customer and contract data for the purpose of establishing, structuring the content of and amending our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only insofar as this is necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The customer data collected is deleted after completion of the order or termination of the business relationship and expiry of any applicable statutory retention periods. Statutory retention periods remain unaffected.

Data transfer upon conclusion of a contract for services and digital content

We transfer personal data to third parties only where this is necessary in the course of performing the contract, for example to the credit institution commissioned to handle the payment.

No further transfer of the data takes place, or only if you have expressly consented to the transfer. Your data is not passed on to third parties without express consent, for example for advertising purposes.

The basis for the data processing is Art. 6(1)(b) GDPR, which permits the processing of data for the performance of a contract or of pre-contractual measures.

Payment services

We integrate payment services from third-party companies on our website. When you make a purchase with us, your payment data (for example name, payment amount, bank details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The payment service providers are used on the basis of Art. 6(1)(b) GDPR (performance of a contract) and in the interest of a payment process that is as smooth, convenient and secure as possible (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for the data processing; consent can be withdrawn at any time with effect for the future.

We use the following payment services / payment service providers within the framework of this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

For details, please refer to PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Unzer

The provider of this payment service is Unzer GmbH, Vangerowstraße 18, 69115 Heidelberg, Germany (hereinafter “Unzer”).

For details, please refer to Unzer’s privacy policy: https://www.unzer.com/de/datenschutz/.

8. Audio and video conferences

Data processing

For communication with our customers we use, among other things, online conference tools. The individual tools we use are listed below. If you communicate with us by video or audio conference via the internet, your personal data is collected and processed by us and by the provider of the respective conference tool.

In doing so, the conference tools record all data that you provide or use in order to use the tools (e-mail address and/or your telephone number). The conference tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “contextual information” in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required to handle the online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Where content is exchanged, uploaded or otherwise made available within the tool, it is likewise stored on the servers of the tool providers. Such content includes in particular cloud recordings, chat and instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared during use of the service.

Please note that we do not have full influence over the data processing operations of the tools used. Our options are largely determined by the corporate policy of the respective provider. For further information on data processing by the conference tools, please refer to the privacy policies of the tools used in each case, which we have listed below this text.

Purpose and legal bases

The conference tools are used in order to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). The use of the tools furthermore serves to generally simplify and accelerate communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Where consent was requested, the tools in question are used on the basis of that consent; consent can be withdrawn at any time with effect for the future.

Storage period

The data we collect directly via the video and conference tools is deleted from our systems as soon as you ask us to delete it, withdraw your consent to storage, or the purpose for storing the data no longer applies. Stored cookies remain on your terminal device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence over the storage period of your data that is stored by the operators of the conference tools for their own purposes. For details on this, please inform yourself directly with the operators of the conference tools.

Conference tools used

We use the following conference tools:

Zoom

We use Zoom. The provider of this service is Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://explore.zoom.us/de/privacy/.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. You can find details here: https://explore.zoom.us/de/privacy/.

Data processing on our behalf

Google Meet

We use Google Meet. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. For details on data processing, please refer to Google’s privacy policy: https://policies.google.com/privacy?hl=de.

Data processing on our behalf

9. E-mail communication

Data protection information

If you contact us by e-mail, we process your personal data only insofar as there is a legitimate interest in the processing (Art. 6(1)(f) GDPR), you have consented to the data processing (Art. 6(1)(a) GDPR), the processing is necessary for the initiation, establishment, structuring of the content or amendment of a legal relationship between you and us (Art. 6(1)(b) GDPR), or another legal provision permits the processing. Your personal data remains with us until you ask us to delete it, withdraw your consent to storage, or the purpose for storing the data no longer applies (for example after your request has been fully processed). Mandatory statutory provisions – in particular retention periods under tax and commercial law – remain unaffected. You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have a right to object, a right to data portability and a right to lodge a complaint with the competent supervisory authority. You may furthermore request the correction, the deletion and, under certain circumstances, the restriction of the processing of your personal data. You can reach our data protection officer at privacy@nemesisconsulting.de.