Steelbearded Games

Privacy policy

Preamble

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

The terms used are gender-neutral.

As of: 28 September 2026

Table of Contents

Controller

Meik Stern, Steelbearded Games
Albert-Einstein-Str. 3 b, 47623 Kevelaer
Germany

Email address: sternmeik@gmail.com

Phone: +49 (0) 172 654 99 30

Legal notice: steelbearded-games.com/legal-notice

Overview of Processing Activities

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

Types of Data Processed

  • Master data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and process data.
  • Log data.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Prospective customers.
  • Communication partners.
  • Users.
  • Business and contractual partners.
  • Third parties.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and usability.
  • Information technology infrastructure.
  • Public relations and information purposes.
  • Public relations.
  • Business processes and operational procedures.

Relevant Legal Bases

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

  • Consent (Art. 6(1)(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfers, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss FADP: This privacy notice serves to provide information under both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used because of their broader territorial application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss FADP, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms continues to be determined in accordance with the Swiss FADP within the scope of its application.

Applicability of data protection regulations in the country of establishment: In the country in which the controller is established, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR).

Security Measures

In accordance with the legal requirements, and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input, disclosure, securing the availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to threats to data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in line with the principles of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect users' data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and in encrypted form.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and in particular conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

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

For data transfers to the USA, we rely primarily on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and set out contractual obligations to protect your data.

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

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Retention and Deletion

We delete the personal data we process in accordance with the legal provisions as soon as the underlying consents are withdrawn or there is no further legal basis for the processing. This applies to cases where the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise or defense of legal claims or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy notices contain additional information on the retention and deletion of data that applies specifically to certain processing activities.

Where there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer retained for its originally intended purpose, but due to legal requirements or other reasons, exclusively for the reasons that justify its retention.

Periods beginning at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the period is the time at which the termination or other ending of the legal relationship takes effect.

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, in accordance with the legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR. The complaint may be lodged in particular with a supervisory authority in the Member State of your habitual residence, your place of work or the place of the alleged infringement.

Business Services

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

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

We process in particular master data such as name, address and, where applicable, company; contact data such as email address and phone number; contract and service data such as the subject matter of the contract, contract term, order or transaction number; usage and service data; payment and billing data; and communication content and history. Where necessary, we also process data disclosed or transmitted to us in the course of carrying out an assignment.

In addition, we process the data to protect our rights and to fulfill legal obligations. This includes in particular retention obligations under commercial and tax law, documentation obligations and, where applicable, obligations of proof and accountability. Processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk management and IT security, as well as in protecting our business operations and our contractual partners against misuse, threats to data, secrets and other legally protected interests. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for the performance of the contract or to fulfill legal obligations.

Personal data is only passed on to third parties insofar as this is necessary for the performance of the contract, for carrying out pre-contractual measures, for safeguarding legitimate interests or for fulfilling legal obligations. We provide separate information in this privacy policy about any processing beyond this, in particular for marketing purposes.

We inform contractual partners of which data is required in each individual case when the data is collected, for example by appropriate labeling in online forms or in personal contact.

The data is deleted as soon as it is no longer required for the aforementioned purposes and no statutory retention obligations prevent deletion. Statutory retention periods, in particular under commercial and tax law, may require longer storage. We delete data transmitted in the context of a specific assignment after completion of the assignment and expiry of any retention periods, unless further legal or contractual obligations to store it exist.

The legal basis for processing is Art. 6(1)(b) GDPR for carrying out pre-contractual measures and for the performance of the respective contractual relationship, and Art. 6(1)(c) GDPR for the fulfillment of legal obligations. Insofar as processing is based on legitimate interests, it takes place on the basis of Art. 6(1)(f) GDPR. Where processing is based on Art. 6(1)(f) GDPR, it serves to safeguard our legitimate interests in a proper and efficient business organization, the internal administration and documentation of business transactions, the enforcement and defense of legal claims, ensuring IT and data security, the prevention of misuse and fraud, and the economic management and further development of our business operations. These interests consist in particular in ensuring secure and legally compliant business operations and in maintaining our entrepreneurial capacity to act.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or phone numbers); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; prospective customers; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and operational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); legal obligation (Art. 6(1)(1)(c) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

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

Payment Procedures

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected against unauthorized access during transmission.

The data processed by the payment service providers includes master data, such as name and address; bank data, such as account numbers or credit card numbers, passwords, TANs and checksums; as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card information, but only information confirming or declining the payment. Under certain circumstances, the payment service providers may transmit the data to credit agencies for the purpose of identity and credit checks. For this, we refer to the terms and conditions and privacy notices of the payment service providers.

The terms and conditions and privacy notices of the respective payment service providers apply to payment transactions and can be accessed on their respective websites or transaction applications. We also refer to these for further information and for exercising rights of withdrawal, access and other data subject rights.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; business and contractual partners; prospective customers.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; business processes and operational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • PayPal: Payment services (technical integration of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

Provision of the Online Services and Web Hosting

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

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved); log data (e.g. log files relating to logins, data retrieval or access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online services and usability; information technology infrastructure (operation and provision of information systems and technical equipment such as computers and servers); security measures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web host"); Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g. to prevent server overload (particularly in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization and stability of the servers; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally resolved.
  • Vercel: Hosting of our online services (provision of storage space and computing capacity, and delivery of the website to visitors' browsers) and collection of server log files; Service provider: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://vercel.com/; Privacy policy: https://vercel.com/legal/privacy-policy. Basis for third-country transfers: Data Privacy Framework (DPF).
  • Cloudflare: Registration and management of our domain, and DNS services (resolving the domain name to the hosting provider's servers); Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.cloudflare.com/; Privacy policy: https://www.cloudflare.com/privacypolicy/; Data processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (part of the data processing agreement).

Contact and Inquiry Management

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

  • Types of data processed: Contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online services and usability.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR).

Further information on processing activities, procedures and services:

  • Contact form: When you contact us via our contact form, by email or through other communication channels, we process the personal data transmitted to us in order to respond to and handle the respective request. This generally includes information such as name, contact information and, where applicable, other information communicated to us that is necessary for the appropriate handling of the request. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).
  • Resend: Sending of the email notifications generated by the request form on our website (transmission of the data entered in the form, such as name, email address, project name, Steam link and stage of the project, to our email inbox); Service provider: Resend, Inc., 2261 Market Street #5039, San Francisco, CA 94114, USA; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://resend.com/; Privacy policy: https://resend.com/legal/privacy-policy; Data processing agreement: https://resend.com/legal/dpa. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (part of the data processing agreement).

Email, Cloud Storage and Office Services

We use software services accessible via the internet and operated on the servers of the respective providers for our email communication and for storing, managing and providing documents. This applies in particular to correspondence with prospective customers and clients, contract-related documents such as agreements and invoices, and the delivery of our work results to clients via shared folders.

The personal data contained in emails and documents is stored and processed on the providers' servers to the extent necessary for communication and for carrying out the respective assignment. When users access shared folders, the provider also processes technical data, such as the IP address.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Prospective customers; communication partners; service recipients and clients; business and contractual partners.
  • Purposes of processing and legitimate interests: Communication; provision of contractual services and fulfillment of contractual obligations; office and organizational procedures; information technology infrastructure.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); legal obligation (Art. 6(1)(1)(c) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Google Workspace (Gmail, Google Drive): Email service and cloud storage for storing and sharing documents; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://workspace.google.com/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (part of the data processing agreement).

Online Forms and Questionnaires

We use an online form service to collect feedback after an assignment has been completed. The information entered into the form is stored on the provider's servers and retrieved by us in order to evaluate the feedback and improve our services. Form data is stored on servers within the European Union.

If you consent in the feedback form to the publication of your feedback (with your name or anonymously), publication takes place on the basis of your consent, which you can withdraw at any time with effect for the future.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Prospective customers; service recipients and clients; communication partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication; feedback (e.g. collecting feedback via online form); marketing.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); consent (Art. 6(1)(1)(a) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Jotform: Creation of online forms and collection, storage and management of the submitted form data; Service provider: Jotform Inc., 4 Embarcadero Center, Suite 780, San Francisco, CA 94111, USA; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.jotform.com/; Privacy policy: https://www.jotform.com/privacy/; Data processing agreement: Provided by the service provider. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses.

Use of AI Services

We use an AI service to support us in evaluating questionnaire answers, analyzing store pages and other materials, and preparing our work results. In this context, content that clients send us as part of an assignment, including any personal data it contains, may be transferred to and processed by the provider. We only transfer content that is necessary for the respective purpose.

We use the service under the provider's commercial terms, which include a data processing agreement. According to the provider, content submitted under these terms is not used to train its AI models. The diagnosis and all recommendations are reviewed by us and remain our responsibility; no decision based solely on automated processing within the meaning of Art. 22 GDPR takes place.

  • Types of data processed: Master data (e.g. full name, residential address, contact information, customer number, etc.); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category).
  • Data subjects: Service recipients and clients; business and contractual partners.
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR); legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Claude (Anthropic): AI assistant supporting analysis, evaluation and writing; Service provider: Anthropic, PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal bases: Performance of a contract and pre-contractual requests (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.anthropic.com/; Privacy policy: https://www.anthropic.com/legal/privacy; Data processing agreement: Part of the commercial terms (https://www.anthropic.com/legal/commercial-terms). Basis for third-country transfers: Standard contractual clauses (part of the data processing agreement).

Social Media Presences

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

Please note that user data may be processed outside the European Union. This may result in risks for users, for example because it could make it more difficult to enforce users' rights.

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

For a detailed description of the respective forms of processing and the options to object (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the exercise of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. Should you nevertheless need assistance, you can contact us.

  • Types of data processed: Contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; feedback (e.g. collecting feedback via online form); public relations; public relations and information purposes.
  • Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Retention and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing activities, procedures and services:

  • Bluesky: Decentralized social media network that enables users to create, share and comment on content and to follow user profiles; Service provider: Bluesky, PBLLC., Seattle, USA, support@bsky.app; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://bsky.social/. Privacy policy: https://bsky.social/about/support/privacy-policy.
  • Reddit: Social network with topic-based communities for publishing, discussing and voting on posts; Service provider: Reddit, Inc., 548 Market St. #16093, San Francisco, CA 94104, USA; contact for users in the EEA: Reddit Netherlands B.V., Keizersgracht 62, 1015 CS Amsterdam, Netherlands; Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR); Website: https://www.reddit.com/. Privacy policy: https://www.reddit.com/policies/privacy-policy.

Changes and Updates

Please check the content of our privacy policy regularly. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or any other individual notification.

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and please check the information before contacting them.

Definitions

This section provides an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration, while the employee performs their work. The employment relationship comprises various phases, including its establishment, in which the employment contract is concluded; its performance, in which the employee carries out their work; and its termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data and performance evaluations.
  • Master data: Master data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unambiguous assignment and communication.
  • Content data: Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data is essential information that enables communication with persons or organizations. It includes, among other things, phone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and process data: Meta, communication and process data are categories that contain information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, timestamps and transmission paths. Process data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages and which paths they take through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a key role in identifying trends, preferences and possible problem areas within digital offerings.
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any form of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.), for example interests in certain content or products, click behavior on a website or location. Cookies and web beacons are often used for profiling purposes.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
  • Controller: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Contract data: Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of critical importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information on payment status, chargebacks, authorizations and fees.

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