Privacy Policy

Privacy Policy for Signagenow.tv. Note on privacy information for our software signagenow.io. Please note that separate privacy terms apply to our SignageNow software (https://app.signagenow.io). You can access them here. Note: The payment terms listed here supplement the plan change and payment options of our software signagenow.io.

Privacy Policy We are very pleased about your interest in our company. Data protection is of particularly high priority for the management of fleiter media GmbH. The use of the website of fleiter media GmbH is generally possible without providing any personal data. However, if a data subject wishes to use special enterprise services via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to fleiter media GmbH. By means of this privacy policy, our enterprise would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights through this privacy policy.

As the controller, fleiter media GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions can fundamentally have security vulnerabilities, meaning absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, such as by telephone.

1. Definitions The privacy policy of fleiter media GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easily readable and understandable for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this privacy policy, we use terms including:

  • a) Personal Data: Any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • b) Data Subject: Any identified or identifiable natural person whose personal data is processed by the controller.
  • c) Processing: Any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • d) Restriction of Processing: The marking of stored personal data with the aim of limiting its processing in the future.
  • e) Profiling: Any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
  • f) Pseudonymization: The processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
  • g) Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  • h) Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
  • i) Recipient: A natural or legal person, public authority, agency, or another body to which the personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
  • j) Third Party: A natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
  • k) Consent: Any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Controller The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions with a data protection character is:

fleiter media GmbH

Dieselstraße 23

59329 Wadersloh

Germany

Phone: +49 (0) 2523 92270

Email: digital@fleiter-media.de

Website: https://www.signagenow.tv

3. Cookies The internet pages of fleiter media GmbH use cookies. Cookies are text files that are stored on a computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain different cookies. A specific internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, fleiter media GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. For example, the website user that uses cookies does not have to enter access data each time the website is accessed, because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the items a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the internet browser used, thus permanently objecting to the setting of cookies. Furthermore, previously set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be entirely usable.

4. Collection of General Data and Information The website of fleiter media GmbH collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using this general data and information, fleiter media GmbH does not draw any conclusions about the data subject. Rather, this information is needed to: (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyberattack. Therefore, fleiter media GmbH analyzes anonymously collected data and information statistically, and further with the aim of increasing the data protection and data security of our enterprise, to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our Website The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may request transfer to one or more processors (e.g., a parcel service) that also uses personal data exclusively for an internal purpose attributable to the controller.

By registering on the website of the controller, the IP address assigned by the Internet Service Provider (ISP) to the data subject, date, and time of registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about the data subject. In addition, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller's employees are available to the data subject in this respect as contact persons.

6. Subscription to our Newsletters On the website of fleiter media GmbH, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data is transmitted to the controller when the newsletter is ordered.

fleiter media GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter shipping. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation email is used for proving whether the owner of the email address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address assigned by the ISP of the computer system used by the data subject at the time of registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in another way.

7. Advertising Conversion Tracking (Google Ads) We place advertisements with Google, including on YouTube. To evaluate how many visitors register with us after interacting with such an ad, we use Google Ads Conversion Tracking based on your consent.

  • Strictly Limited Scope: This measurement takes place exclusively on the registration page and the immediately following confirmation page. No Google services are loaded in any other areas of SignageNow. Specifically:
    • No tracking occurs while working within the software;
    • Your user behavior within the application is not analyzed;
    • We do not create user profiles or perform general web analytics;
    • The contents of your playlists, media, or screens are not tracked.
  • Legal Basis: This processing takes place exclusively based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. Without your consent, no advertising cookies are set and no identifiers are transmitted to Google. The use of SignageNow is completely independent of this—declining consent will not result in any disadvantages.
  • Processed Data: Upon granted consent, the following are processed:
    • A click identifier assigned by Google (gclid, gbraid, or wbraid), provided you reached us via one of our ads;
    • A cookie for click recognition (_gcl_au, storage period up to 90 days);
    • Your IP address as well as browser, operating system, and access timestamp details;
    • Information that a registration was completed on our website.
    • We do not transmit names, email addresses, or other master data to Google. We do not evaluate your behavior within the application; only the completion of a registration is reported.
  • Consent Mode: We implement Google Consent Mode. As long as you have not consented, no identifiers are stored or read. In this case, Google receives only a ping without identifying traits, from which exclusively statistical estimates are generated.
  • Proof of Decision: We must be able to demonstrate whether and to what you consented (Art. 7 (1) GDPR). For this purpose, we log the following for every decision (consent, refusal, and subsequent revocation): a randomly generated identifier without reference to your name or account, the decision itself, its timestamp, the version of the consent text, the accessed page and language setting, your browser user agent, and your IP address in the form of an irreversible hash value. The IP address itself is not stored. The legal basis is our legal obligation to provide proof (Art. 6 (1) (c) in conjunction with Art. 7 (1) GDPR).
  • Recipient: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  • Third-Country Transfer: Processing in the USA by Google LLC cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework, meaning an adequacy decision by the European Commission exists. Standard Contractual Clauses are also in place. Please note that US authorities may access this data under certain conditions and legal protection fully equivalent to European standards may not be guaranteed in all cases.
  • Storage Duration: Cookies set by Google are deleted after 90 days at the latest. We store your consent decision for 6 months so that we do not have to prompt you on every visit. Proof of this decision is retained for three years and deleted automatically thereafter.
  • Revocation: You may revoke your consent at any time with effect for the future. The legality of the processing carried out up to the revocation remains unaffected. [Revoke consent now]
  • Further information on how Google handles user data can be found in Google's Privacy Policy.

8. Newsletter Tracking The newsletters of fleiter media GmbH contain tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, fleiter media GmbH can see if and when an email was opened by a data subject, and which links in the email were called up.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller to optimize the newsletter delivery and tailor future newsletters even better to the interests of the data subject. This personal data is not transferred to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent granted via the double opt-in procedure. After revocation, these personal data will be deleted by the controller. An unsubscription from the receipt of the newsletter is automatically interpreted by fleiter media GmbH as a revocation.

9. Contact Possibility via the Website The website of fleiter media GmbH contains information required by statutory regulations that allows quick electronic communication and direct contact with us, including a general email address. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

10. Routine Erasure and Blocking of Personal Data The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the storage purpose, or as long as granted by the European legislator or other lawmakers in applicable regulations.

If the storage purpose is not applicable, or if an expiration period prescribed by the European legislator or other competent legislators expires, the personal data are routinely blocked or erased in accordance with legal requirements.

11. Rights of the Data Subject

  • a) Right of Confirmation: Each data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether or not personal data concerning them are being processed.
  • b) Right of Access: Each data subject has the right to obtain free information about their stored personal data and a copy of this information at any time, including:
    • The purposes of the processing;
    • The categories of personal data concerned;
    • The recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly recipients in third countries or international organizations;
    • Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
    • The existence of the right to request rectification or erasure of personal data or restriction of processing, or to object to such processing;
    • The existence of the right to lodge a complaint with a supervisory authority;
    • Where personal data are not collected from the data subject, any available information as to their source;
    • The existence of automated decision-making, including profiling (Art. 22 (1), (4) GDPR) and meaningful information about the logic involved, as well as the significance and envisaged consequences.
    • Furthermore, the data subject has the right to be informed whether personal data are transferred to a third country or to an international organization and the appropriate safeguards relating to the transfer.
  • c) Right to Rectification: Each data subject has the right to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of processing, the data subject also has the right to have incomplete personal data completed, including by providing a supplementary statement.
  • d) Right to Erasure (Right to Be Forgotten): The data subject has the right to obtain the erasure of personal data concerning them without undue delay where one of the statutory grounds applies and processing is not necessary.
    • If fleiter media GmbH has made personal data public and is obliged pursuant to Art. 17 (1) GDPR to erase the data, fleiter media GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps (including technical measures) to inform other controllers processing the personal data that the data subject has requested erasure of any links to, or copy or replication of, those personal data.
  • e) Right to Restriction of Processing: The data subject has the right to obtain restriction of processing where the accuracy of the data is contested, the processing is unlawful, the controller no longer needs the data for processing but the data subject requires it for legal claims, or an objection pursuant to Art. 21 (1) GDPR is pending verification.
  • f) Right to Data Portability: The data subject has the right to receive their personal data provided to a controller in a structured, commonly used, and machine-readable format, and to transmit those data to another controller without hindrance, where processing is based on consent or a contract and carried out by automated means. The data subject also has the right to have the personal data transmitted directly from one controller to another where technically feasible.
  • g) Right to Object: The data subject has the right to object at any time, on grounds relating to their particular situation, to processing of personal data concerning them based on Art. 6 (1) (e) or (f) GDPR, including profiling. fleiter media GmbH shall no longer process the personal data unless compelling legitimate grounds can be demonstrated. Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time.
  • h) Automated Individual Decision-Making, Including Profiling: The data subject has the right not to be subject to a decision based solely on automated processing—including profiling—which produces legal effects concerning them or similarly significantly affects them, subject to statutory exceptions.
  • i) Right to Withdraw Data Protection Consent: The data subject has the right to withdraw their consent to the processing of personal data at any time.

12. Data Protection for Applications and Application Procedures The controller collects and processes the personal data of applicants for the purpose of managing the application procedure. Processing may also take place electronically (e.g., via email or web forms). If an employment contract is concluded with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with statutory provisions. If no employment contract is concluded, the application documents will be deleted automatically two months after notification of the rejection decision, provided that no other legitimate interests of the controller (e.g., duty to provide evidence under the German General Equal Treatment Act / AGG) oppose deletion.

13. Privacy Provisions for the Use of Google AdSense The controller has integrated Google AdSense on this website. Google AdSense is an online service that enables the placement of advertisements on third-party sites via algorithms matching ad content to the context of the respective site. Google AdSense allows interest-based targeting via individual user profiles.

  • Operating Company: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
  • Functionality: Google AdSense places a cookie on the data subject's computer system to analyze website usage. With each page view, the browser automatically transmits data to Alphabet Inc. for online advertising and commission accounting. Alphabet Inc. obtains personal data such as the IP address to track visitor origin and clicks.
  • Tracking Pixels: Google AdSense also uses tracking pixels (embedded miniature graphics) to record and analyze log files and assess traffic flows. Data (including IP address) is transferred to Alphabet Inc. in the United States of America, where it is stored, processed, and potentially shared with third parties.
  • Opt-out: The data subject can prevent the setting of cookies at any time through browser settings or delete existing cookies. Further details are available at: https://www.google.de/intl/de/adsense/start/

14. Privacy Provisions for the Use of Google Analytics (with Anonymization Function) The controller has integrated Google Analytics (with anonymization function) on this website. Google Analytics is a web analytics service used to collect and analyze data on visitor behavior (referrers, subpages visited, visit duration).

  • Operating Company: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
  • IP Anonymization: We use the operator extension "_gat._anonymizeIp", which truncates and anonymizes the IP address if access occurs from an EU/EEA member state.
  • Cookies & Data Transfer: Google Analytics sets a cookie on the user's system to analyze site usage. Personal data (including IP address, access time, location, visit frequency) is transferred to Google in the United States and stored there. Google may pass this data to third parties.
  • Opt-out: Setting of cookies can be blocked or deleted via browser settings. Users can also prevent data collection and processing by Google by downloading and installing the browser add-on available at: https://tools.google.com/dlpage/gaoptout. Further terms and policies: https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html.

15. Privacy Provisions for the Use of Google Remarketing The controller has integrated Google Remarketing services. Google Remarketing is a Google Ads feature enabling an enterprise to display targeted, interest-relevant ads to users who previously visited the enterprise's website.

  • Operating Company: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
  • Functionality: Google Remarketing sets a cookie enabling Google to recognize returning visitors across the Google Advertising Network. Personal data (such as IP address and browsing behavior) is transferred to and stored by Google in the United States.
  • Opt-out: Cookie settings can be managed via the browser. Users can also opt out of interest-based advertising via Google Ads settings at: www.google.de/settings/ads.

16. Privacy Provisions for the Use of LinkedIn The controller has integrated components of the LinkedIn Corporation on this website.

  • Operating Company: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For privacy matters outside the USA: LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
  • Functionality: Each time a page with a LinkedIn plug-in is loaded, the browser downloads the component from LinkedIn, informing LinkedIn which specific subpage was accessed. If the data subject is logged in to LinkedIn simultaneously, LinkedIn tracks and associates visits to their account. Interaction with plug-ins (e.g., clicking the button) transmits data directly to LinkedIn.
  • Prevention & Settings: Logging out of LinkedIn prior to visiting the website prevents account association. Ad and notification settings can be managed at: https://www.linkedin.com/psettings/guest-controls. Cookie opt-outs and privacy policies: https://www.linkedin.com/legal/cookie-policy and https://www.linkedin.com/legal/privacy-policy.

17. Privacy Provisions for the Use of Matomo The controller has integrated the Matomo component on this website. Matomo is an open-source web analysis tool.

  • Hosting: The software is operated on the controller's own server; privacy-sensitive log files are stored exclusively on this server without third-party transfer.
  • Functionality: Matomo sets a cookie to analyze website traffic, capturing data such as IP address, access time, and referrer.
  • Opt-out: Cookie placement can be blocked via browser settings or by enabling "Do Not Track" headers in the browser. Further info: https://matomo.org/privacy/.

18. Payment Method: Klarna The controller has integrated Klarna components. Klarna is an online payment provider offering invoice purchasing, flexible installment plans, buyer protection, and identity/credit checks.

  • Operating Company: Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.
  • Data Processing: Selecting "Invoice" or "Installment Purchase" automatically transmits data to Klarna (first name, last name, address, date of birth, gender, email, IP address, phone number, payment/bank details, items ordered, and past purchase history).
  • Purpose & Credit Checks: Data transfer serves identity verification, payment administration, fraud prevention, and credit scoring via credit agencies. Klarna may share data within the Klarna Group and with subcontractors.
  • Revocation & Policy: Consent can be revoked directly with Klarna, excluding data required for contractual payment processing. Policy: https://cdn.klarna.com/1.0/shared/content/policy/data/de_de/data_protection.pdf.

19. Payment Method: PayPal The controller has integrated PayPal components. PayPal is an online payment service provider handling virtual accounts and credit card processing.

  • European Operating Company: PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449, Luxembourg.
  • Data Processing: Selecting PayPal transmits personal details (name, address, email, IP address, phone number, and order details) to PayPal for transaction processing and fraud prevention. PayPal may transmit data to credit agencies for identity and credit checks.
  • Policy: Consent can be revoked directly with PayPal. Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

20. Payment Method: Sofortüberweisung The controller has integrated Sofortüberweisung components (direct bank transfer service).

  • Operating Company: Klarna Bank AB, Sveavägen 46, 111 34 Stockholm, Sweden.
  • Data Processing: The buyer submits PIN and TAN details to Sofort GmbH. Sofortüberweisung checks account balances and automatically executes the transfer, notifying the merchant immediately. Transmitted data includes name, address, email, IP address, and order information for payment execution and fraud prevention.
  • Policy: Policy: https://www.klarna.com/sofort/datenschutz/.

21. Legal Basis of Processing

  • Art. 6 (1) (a) GDPR: Serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose.
  • Art. 6 (1) (b) GDPR: Applies if processing personal data is necessary for the performance of a contract (e.g., delivery of goods, provision of services) or pre-contractual measures (e.g., inquiries).
  • Art. 6 (1) (c) GDPR: Applies if our company is subject to a legal obligation requiring data processing (e.g., tax compliance).
  • Art. 6 (1) (d) GDPR: Applies in rare cases where processing is necessary to protect vital interests of the data subject or another natural person.
  • Art. 6 (1) (f) GDPR: Serves as the basis for processing operations necessary for the legitimate interests pursued by our company or a third party, except where overridden by the interests, fundamental rights, and freedoms of the data subject (e.g., when the data subject is a customer, Recital 47 GDPR).

22. Legitimate Interests Pursued by the Controller or a Third Party Where the processing of personal data is based on Article 6 (1) (f) GDPR, our legitimate interest is the performance of our business activities for the well-being of all our employees and shareholders.

23. Duration for Which Personal Data Is Stored The criterion for the duration of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, provided it is no longer necessary for the fulfillment or initiation of a contract.

24. Statutory or Contractual Provisions for Providing Personal Data; Contract Requirement; Obligation of the Data Subject; Consequences of Failure to Provide The provision of personal data is partly required by law (e.g., tax regulations) or may result from contractual provisions (e.g., information on the contractual partner). At times, concluding a contract requires the data subject to provide personal data that we must subsequently process. Failure to provide personal data would mean the contract cannot be concluded. Before providing personal data, the data subject may contact our staff to clarify whether the provision is legally or contractually required and the consequences of non-provision.

25. Existence of Automated Decision-Making As a responsible enterprise, we do not use automatic decision-making or profiling.

Developed by the LegalTech specialists at Willing & Able, who also developed the system for GDPR processing activities records. The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.

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