Privacy Policy

We are very pleased that you are interested in our company. Data protection is a top priority for Softrase’s management. In general, you can use Softrase’s website without providing any personal data. However, if a data subject wishes to use specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the data subject’s consent.

The processing of personal data—such as a data subject’s name, address, email address, or phone number 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 Softrase. Through this Privacy Policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy informs data subjects of their rights.

As the data controller, Softrase has implemented numerous technical and organizational measures to ensure the most comprehensive protection possible of the personal data processed via this website. Nevertheless, internet-based data transmissions may generally involve security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide personal data to us through alternative means, such as by telephone.

1. Definition Softrase’s Privacy Policy is based on the terminology used by European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this Privacy Policy, we use the following terms, among others:

a) Personal Data Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
b) Data Subject A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing Processing means any operation or set of operations performed on 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, the matching or linking, the restriction, erasure, or destruction.
d) Restriction of processing Restriction of processing means the marking of stored personal data with the aim of limiting its future processing.
e) Profiling Profiling is any form of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
f) Pseudonymization Pseudonymization is the processing of personal data in such a way 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 that ensure the personal data is not attributed to an identified or identifiable natural person.
g) Data Controller The controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data. If the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for under Union law or the law of the Member States.
h) Processor A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
i) Recipient A recipient is a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, regardless of whether or not that entity is a third party. However, public authorities that may receive personal data in the course of a specific investigative mandate under Union law or the law of the Member States are not considered recipients.
j) Third Party A third party is a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
k) Consent Consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, expressed by a statement or by a clear affirmative action, by which the data subject signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the Data 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 of a data protection nature is:

3. Cookies The Softrase website uses cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain what is known as a cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that allows websites and servers to associate the cookie with the specific web browser in which it was stored. This enables the visited websites and servers to distinguish the data subject’s individual browser from other web browsers that contain different cookies. A specific web browser can be recognized and identified via the unique cookie ID.

By using cookies, Softrase can provide users of this website with more user-friendly services that would not be possible without setting cookies.

Cookies allow us to optimize the information and offerings on our website to better serve the user’s needs.

As mentioned above, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re- enter their login credentials every time they visit the website, because this information is handled by the website and the cookie stored on the user’s computer system. Another example is the shopping cart cookie in an online store. The online store uses a cookie to remember the items a customer has placed in the virtual shopping cart.

The data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser they are using, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programs. This is possible in all common web browsers. If the data subject disables the setting of cookies in the web browser they are using, not all functions of our website may be fully usable under certain circumstances.

4. Collection of General Data and Information The Softrase website collects a range of general data and information each time a data subject or an automated system accesses the website.

This general data and information is stored in the server’s log files. The following may be collected: (1) the 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 (known as the referrer), (4) the subpages on our website accessed via the accessing system, (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) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, Softrase does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimize the content of our website and the advertising on it, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. Softrase therefore evaluates this anonymously collected data and information both for statistical purposes and with the aim of enhancing data protection and data security within our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

5. Contact Options via the Website In accordance with legal requirements, the Softrase website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general electronic mail address (email address). If a data subject contacts the data controller via email or a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, transmitted voluntarily by a data subject to the data controller, is stored for the purposes of processing the request or contacting the data subject

This personal data is not disclosed to third parties.

6. Comment Function on the Website’s Blog Softrase offers users the opportunity to leave individual comments on specific blog posts on a blog located on the data controller’s website. A blog is a portal hosted on a website, typically accessible to the public, where one or more individuals-known as bloggers or web bloggers—can post articles or share their thoughts in so-called blog posts. These blog posts can generally be commented on by third parties.

If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, information regarding the time the comment was submitted and the username (pseudonym) chosen by the data subject is also stored and published. Furthermore, the IP address assigned by the data subject’s Internet service provider (ISP) is also logged. This IP address is stored for security reasons and in the event that the data subject infringes the rights of third parties through a comment or posts unlawful content. The storage of this personal data is therefore in the data controller’s own interest, so that the data controller may, if necessary, exonerate itself in the event of a legal violation. This collected personal data is not disclosed to third parties unless such disclosure is required by law or serves to defend the data controller’s legal rights.

7. Routine Deletion and Blocking of Personal Data The data controller processes and stores the data subject’s personal data only for the

period necessary to achieve the purpose of storage or to the extent provided for by the European legislative bodies or other competent authorities in laws or regulations to which the data controller is subject.

If the purpose of storage no longer applies or if a retention period prescribed by the European legislative and regulatory authorities or another competent legislative authority expires, the personal data will be routinely blocked or deleted in accordance with legal requirements.

8. Rights of the Data Subject a) Right to Confirmation Every data subject has the right, granted by the European legislative and regulatory authorities, to request confirmation from the data controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact a representative of the data controller at any time.

b) Right of Access Every data subject affected by the processing of personal data has the right, granted by the European legislator, to receive from the controller, at any time and free of charge, information regarding the personal data stored about them and a copy of such information. Furthermore, the European legislator has granted the data subject the right to receive information regarding the following:

the purposes of the processing
the categories of personal data being processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining that duration the existence of a right to have the personal data concerning them rectified or erased, or to have processing restricted by the controller, or a right to object to such processing
the existence of a right to lodge a complaint with a supervisory authority
if the personal data are not collected from the data subject: all available information regarding the origin of the data the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and at least in such cases- meaningful information regarding the logic involved, as well as the scope and intended consequences of such processing for the data subject

Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to receive information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right of access, they may contact a representative of the data controller at any time.

c) Right to Rectification Every data subject affected by the processing of personal data has the right, granted by European legislation, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data—including by means of a supplementary statement-taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, they may contact a representative of the data controller at any time.

d) Right to Erasure (Right to Be Forgotten) Every data subject affected by the processing of personal data has the right, granted by European legislation, to request that the controller erase personal data concerning them without undue delay, provided that one of the following grounds applies and insofar as the processing is not necessary:

The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
The data subject withdraws their consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data has been processed unlawfully.
The erasure of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data was collected in connection with information society services offered pursuant to Article 8(1) of the GDPR.

If any of the above reasons apply and a data subject wishes to request the erasure of personal data stored by Softrase, they may contact a representative of the controller at any time. The Softrase representative will ensure that the erasure request is complied with without delay.

If the personal data has been made public by Softrase and our company, as the controller, is obligated to erase the personal data pursuant to Article 17(1) of the GDPR, Softrase shall take appropriate measures, including technical measures, taking into account available technology and implementation costs, to inform other controllers processing the published personal data that the data subject has requested that these other data controllers delete all links to such personal data or copies or replicas of such personal data, provided that the processing is not necessary. The Softrase employee will take the necessary steps on a case-by-case basis.

e) Right to Restriction of Processing

Every data subject affected by the processing of personal data has the right, granted by European legislation, to request from the controller to restrict processing if one of the following conditions is met:

The data subject disputes the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, the data subject objects to the erasure of the personal data, and instead requests the restriction of the use of the personal data.
The controller no longer needs the personal data for the purposes of processing, but the data subject needs it to assert, exercise, or defend legal claims.
The data subject has objected to the processing pursuant to Art. 21(1) of the GDPR, and it has not yet been determined whether the controller’s legitimate grounds override those of the data subject.

If any of the above conditions are met and a data subject wishes to request the restriction of personal data stored by Softrase, they may contact a representative of the data controller at any time. The Softrase representative will arrange for the restriction of processing.

f) Right to Data Portability

Every data subject affected by the processing of personal data has the right, granted by European legislation, to receive the personal data concerning them-which the data subject has provided to a controller-in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) of the GDPR or Art. 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another controller, provided that this is technically feasible and does not infringe upon the rights and freedoms of others. To exercise the right to data portability, the data subject may contact a Softrase employee at any time.

g) Right to Object

Any data subject affected by the processing of personal data has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them that is carried out pursuant to Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

In the event of an objection, Softrase will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defense of legal claims. If Softrase processes personal data for the purpose of

direct marketing, the data subject has the right to object at any time to the processing of personal data for the purposes of such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Softrase regarding processing for direct marketing purposes, Softrase will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her that is carried out by Softrase for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact any Softrase employee or another employee directly. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures that use technical specifications.

h) Automated Individual Decision-Making, Including Profiling Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing-including profiling—that produces legal effects concerning the data subject or similarly significantly affects the data subject, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is based on Union or Member State law to which the controller is subject permits such processing, and such law provides for appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject; or (3) is based on the explicit consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Softrase shall take appropriate measures to safeguard the data subject’s rights and freedoms as well as their legitimate interests, including at a minimum the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

If the data subject wishes to exercise rights relating to automated decision-making, they may contact an employee of the data controller at any time.

i) Right to Withdraw Consent Under Data Protection Law Every data subject affected by the processing of personal data has the right, granted by European legislation, to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact a representative of the data controller at any time.

9. Data Protection in Connection with Job Applications and the Application Process The data controller collects and processes the personal data of job applicants for the purpose of conducting the application process. Processing may also take place electronically. This is particularly the case when an applicant submits the relevant application documents to the data controller electronically, for example via email or through a web form on the website. If the data controller enters into an employment contract with an applicant, the data provided will be stored for the purpose of administering the employment relationship in accordance with legal requirements. If the data controller does not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

10. Privacy Policy Regarding the Use of AddThis The data controller has integrated components from the company AddThis into this website. AddThis is a so-called bookmarking provider. The service enables users to easily bookmark web pages using buttons. Hovering over the AddThis component with the mouse or clicking on it displays a list of bookmarking and sharing services. AddThis is used on over 15 million websites, and according to the operating company, the buttons are displayed over 20 billion times annually.

The operator of AddThis is Oracle Corporation, 10 Van de Graaff Drive, Burlington, MA 01803, USA.

Each time a user visits one of the individual pages of this website, which is operated by the data controller and on which an AddThis component has been integrated, the web browser on the data subject’s computer system is automatically prompted by the respective AddThis component to download data from the website www.addthis.com. As part of this technical process, AddThis learns of the visit and which specific page of this website is accessed by the data subject’s computer system. Furthermore, AddThis obtains information regarding the IP address assigned by the Internet service provider (ISP) to the computer system used by the data subject, the browser type, the browser language, the website visited prior to our website, and the date and time of the visit to our website. AddThis uses this data to create anonymized user profiles. The data and information transmitted to AddThis in this manner enable AddThis itself, as well as its affiliated companies or partner companies, to target visitors to the data controller’s websites with personalized and interest-based advertising.

AddThis displays personalized and interest-based advertising based on a cookie set by the company.

This cookie analyzes the individual browsing behavior of the computer system used by the data subject. The cookie records visits to websites originating from the computer system.

As described above, the data subject may prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the web browser would also prevent AddThis from setting a cookie on the data subject’s computer system. In addition, cookies already set by AddThis can be deleted at any time via a web browser or other software programs.

The data subject also has the option to permanently object to the processing of personal data by AddThis. To do so, the data subject must click the opt-out button at the link

http://www.addthis.com/privacy/opt-out, which sets an opt-out cookie. The opt-out cookie set upon objection is stored on the data subject’s computer system. If the cookies are deleted from the data subject’s system after an objection has been raised, the data subject must access the link again and set a new opt-out cookie.

However, setting the opt-out cookie may result in the data subject no longer being able to fully use the data controller’s websites.

AddThis’s current privacy policy can be accessed at http://www.addthis.com/privacy/privacy-policy.

11. Privacy Policy Regarding the Use of Facebook The data controller has integrated components from Facebook into this website. Facebook is a social network.

A social network is a social gathering place operated on the Internet-an online community that generally enables users to communicate with one another and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or enable the online community to share personal or business-related information. Among other things, Facebook allows users of the social network to create private profiles, upload photos, and connect with others through friend requests.

Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The controller

personal data, if a data subject resides outside the United States or Canada, is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time a user visits one of the individual pages of this website-which is operated by the data controller and on which a Facebook component (Facebook plug-in) has been integrated-the user’s web browser on their computer system is automatically prompted by the respective Facebook component to download a representation of that Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at

https://developers.facebook.com/docs/plugins/?locale=de_DE . As part of this technical process, Facebook learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into Facebook at the same time, Facebook recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website.

This information is collected by the Facebook component and assigned by Facebook to the data subject’s respective Facebook account. If the data subject clicks one of the Facebook buttons integrated into our website—for example, the “Like” button—or posts a comment, Facebook assigns this information to the data subject’s personal Facebook user account and stores this personal data.

Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged into Facebook at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If

the data subject does not wish for this information to be transmitted to Facebook, they can prevent the transmission by logging out of their Facebook account before visiting our website.

The Privacy Policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about Facebook’s collection, processing, and use of personal data. It also explains the settings options Facebook offers to protect the data subject’s privacy. In addition, various applications are available that allow users to prevent data from being transmitted to Facebook. Data subjects may use such applications to prevent data from being transmitted to Facebook.

12. Privacy Policy Regarding the Use of Google AdSense The data controller has integrated Google AdSense into this website. Google AdSense is an online service that facilitates the placement of advertisements on third-party websites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party websites to match the content of the respective third-party website. Google AdSense allows for interest-based targeting of internet users, which is implemented by generating individual user profiles.

The operator of the Google AdSense component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of the Google AdSense component is to integrate advertisements on our website. Google AdSense sets a cookie on the data subject’s information technology system. What cookies are has already been explained above. Setting the cookie enables Alphabet Inc. to analyze the use of our website. With

each time a user visits one of the individual pages of this website-which is operated by the data controller and on which a Google AdSense component has been integrated- the web browser on the data subject’s IT system is automatically prompted by the respective Google AdSense component to transmit data to Alphabet Inc. for the purposes of online advertising and commission billing. As part of this technical process, Alphabet Inc. obtains personal data, such as the data subject’s IP address, which Alphabet Inc. uses, among other things, to track the origin of visitors and clicks and, consequently, to enable commission settlements.

As described above, the data subject may prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the user’s web browser would also prevent Alphabet Inc. from setting a cookie on the data subject’s computer system. In addition, a cookie already set by Alphabet Inc. can be deleted at any time via the web browser or other software programs.

Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic embedded in web pages to enable log file recording and analysis, which allows for statistical evaluation. Using the embedded web beacon, Alphabet Inc. can determine whether and when a web page was opened by a data subject and which links were clicked by the data subject. Web beacons are used, among other things, to analyze website traffic.

Through Google AdSense, personal data and information- including the IP address, which is necessary for tracking and billing the displayed advertisements—are transmitted to Alphabet Inc. in the United States of America

. This personal data is stored and processed in the United States of America. Alphabet Inc. may, under certain circumstances, disclose this personal data—collected through technical means to third parties.

Google AdSense is explained in more detail at this link: https://www.google.de/intl/de/adsense/start/.

13. Privacy Policy Regarding the Use of Google Analytics (with Anonymization Function) The data controller has integrated the Google Analytics component (with anonymization feature) into this website. Google Analytics is a web analytics service. Web analytics refers to the collection, gathering, and evaluation of data regarding the behavior of website visitors. Among other things, a web analytics service collects data on which website a data subject came from to access a website (known as a “referrer”), which subpages of the website were accessed, and how often and for how long a subpage was viewed. Web analytics is primarily used to optimize a website and to perform a cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The data controller uses the parameter

“_gat._anonymizelp” for web analytics via Google

Analytics. This parameter causes Google to truncate and anonymize the IP address of the data subject’s Internet connection when access to our website occurs from a member state of the European Union or from another signatory state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information collected, among other things, to

evaluate the use of our website, to compile online reports for us that illustrate the activity on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s information technology system. What cookies are has already been explained above. Placing the cookie enables Google to analyze the use of our website. Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Google Analytics component has been integrated-the web browser on the data subject’s IT system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains personal data, such as the data subject’s IP address, which Google uses, among other things, to track the origin of visitors and clicks and, consequently, to enable commission settlements.

Through the use of cookies, personal information—such as the time of access, the location from which access originated, and the frequency of the data subject’s visits to our website- is stored. Each time our website is visited, this personal data-including the IP address of the internet connection used by the data subject is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personal data collected through the technical process to third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser being used

and thus permanently object to the setting of cookies. Such a setting in the Internet browser would also prevent Google from setting a cookie on the data subject’s information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by Google Analytics relating to the use of this website, as well as the processing of such data by Google. To do so, the data subject must download and install a browser add-on from the link

https://tools.google.com/dlpage/gaoptout. This browser add- on uses JavaScript to instruct Google Analytics that no data or information regarding website visits may be transmitted to Google Analytics. Google considers the installation of the browser add-on to be an objection. If the data subject’s computer system is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to deactivate Google Analytics.

If the browser add-on is uninstalled or deactivated by the data subject or another person within their control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable privacy policies can be found at

https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

14. Privacy Policy Regarding the Use of Google Remarketing The data controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing therefore allows a company to create user- specific advertisements and, consequently, to display ads relevant to the user’s interests.

The operator of Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is to display interest- based advertisements. Google Remarketing enables us to display advertisements via the Google Display Network or on other websites that are tailored to the individual needs and interests of internet users.

Google Remarketing places a cookie on the data subject’s computer system. What cookies are has already been explained above. By placing this cookie, Google is able to recognize visitors to our website when they subsequently visit websites that are also part of the Google Display Network. Each time a website on which the Google Remarketing service has been integrated is accessed, the data subject’s web browser automatically identifies itself to Google. As part of this technical process, Google obtains personal data, such as the user’s IP address or browsing behavior, which Google uses, among other things, to display interest-based advertisements.

Personal information—such as the websites visited by the data subject—is stored via cookies. Each time our

websites, personal data—including the IP address of the internet connection used by the data subject—is therefore transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personal data collected through the technical process to third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the internet browser would also prevent Google from setting a cookie on the data subject’s computer system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do so, the data subject must access the linkwww.google.de/settings/ads from each of the web browsers they use and configure the desired settings there.

Further information and Google’s applicable privacy policy can be found at https://

andwww.google.de/intl/de/policies/privacy/.

15. Privacy Policy Regarding the Use of Google+ The data controller has integrated the Google+ button as a component on this website. Google+ is a so-called social network. A social network is a social meeting place operated on the Internet—an online community that generally enables users to communicate with one another and interact in a

virtual space. A social

network can serve as a platform for exchanging opinions and experiences or enable the online community to share personal or business-related information. Among other things, Google+ allows users of the social network to create private profiles, upload photos, and connect with others through friend requests.

The operator of Google+ is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Each time a user visits one of the individual pages of this website-which is operated by the data controller and on which a Google+ button has been integrated-the web browser on the data subject’s computer is automatically prompted by the respective Google+ button to download a representation of the corresponding Google+ button from Google. As part of this technical process, Google learns which specific subpage of our website the data subject is visiting. More detailed information about Google+ is available at https://developers.google.com/+/

If the data subject is logged into Google+ at the same time, Google recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected via the Google+ button and assigned by Google to the data subject’s respective Google+ account.

If the data subject clicks one of the Google+ buttons integrated into our website and thereby submits a Google+1 recommendation, Google associates this information with the data subject’s personal Google+ user account and stores this personal data. Google stores the data subject’s Google+1 recommendation and makes it publicly accessible in accordance with the terms and conditions accepted by the data subject in this regard

. A Google+1 recommendation submitted by the data subject on this website is subsequently stored and processed together with other personal data—such as the name of the Google+1 account used by the data subject and the photo associated with that account—in other Google services, such as the search results of the Google search engine, the data subject’s Google Account, or in other locations, such as on websites or in connection with advertisements.

Furthermore, Google is able to link the visit to this website with other personal data stored by Google. Google also records this personal information for the purpose of improving or optimizing its various services.

Google receives information via the Google+ button that the data subject has visited our website whenever the data subject is logged into Google+ at the time of accessing our website; this occurs regardless of whether the data subject clicks on the Google+ button or not.

If the data subject does not wish to have personal data transmitted to Google, they can prevent such transmission by logging out of their Google+ account before visiting our website.

Further information and Google’s applicable privacy policy can be found at

https://www.google.de/intl/de/policies/privacy/. Additional information from Google regarding the Google+1 button can be found at https://developers.google.com/+/web/buttons- policy.

16. Privacy Policy Regarding the Use of Google AdWords The data controller has integrated Google AdWords into this website. Google AdWords is an online advertising service that allows advertisers to place ads both in Google’s search engine results and on the Google Display Network. Google AdWords enables an advertiser to specify certain keywords in advance, so that an ad is displayed in Google’s search results only when a user enters a keyword-relevant search query into the search engine. Within the Google Display Network, ads are distributed across thematically relevant websites using an automated algorithm and in accordance with the previously specified keywords.

The operator of the Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google AdWords is to promote our website by displaying interest-based advertisements on third-party websites and in Google’s search results, as well as by displaying third-party advertisements on our website.

If a data subject arrives at our website via a Google ad, Google places a so-called conversion cookie on the data subject’s computer system. What cookies are has already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. Provided the cookie has not yet expired, the conversion cookie is used to track whether certain subpages—such as the shopping cart of an online store system—on our website have been accessed. The conversion cookie allows both us and Google to track whether a data subject who arrived at our website via an AdWords ad generated revenue—that is, whether they completed or abandoned a purchase.

The data and information collected through the use of the conversion cookie are used by Google to generate visitor statistics for our website. We, in turn, use these visitor statistics to determine the total number of users who were referred to us via AdWords ads—that is, to assess the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the data subject.

The conversion cookie is used to store personal information, such as the web pages visited by the data subject. Consequently, each time our website is visited, personal data-including the IP address of the internet connection used by the data subject—is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personal data—collected through technical means—to third parties.

As described above, the data subject can prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the user’s web browser would also prevent Google from setting a conversion cookie on the data subject’s computer system. In addition, a cookie already set by Google AdWords can be deleted at any time via the web browser or other software programs.

Furthermore, the data subject has the option to object to interest-based advertising by Google. To do so, the data subject must, for each of the

Open your web browser from the linkwww.google.de/settings/ads and configure the desired settings there.

Further information and Google’s applicable privacy policy can be found at https://

andwww.google.de/intl/de/policies/privacy/.

17. Privacy Policy Regarding the Use of Instagram The data controller has integrated components of the Instagram service into this website. Instagram is a service that qualifies as an audiovisual platform and enables users to share photos and videos, as well as to redistribute such content on other social networks.

The operator of Instagram’s services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time a user visits one of the individual pages of this website-which is operated by the data controller and on which an Instagram component (Instagram button) has been integrated-the web browser on the data subject’s computer is automatically prompted by the respective Instagram component to download a representation of the corresponding Instagram component. As part of this technical process, Instagram learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into Instagram at the same time, Instagram recognizes which specific subpage the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the Instagram component and assigned by Instagram to the data subject’s respective Instagram account. If the data subject clicks on one of the

our website, the data and information transmitted through it are associated with the data subject’s personal Instagram user account and are stored and processed by Instagram.

Instagram receives information via the Instagram component that the data subject has visited our website whenever the data subject is logged into Instagram at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not wish for this information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before visiting our website.

Further information and Instagram’s applicable privacy policy can be found at

https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/ .

18. Privacy Policy Regarding the Use of Jetpack for WordPress The data controller has integrated Jetpack into this website. Jetpack is a WordPress plugin that offers additional features to the operator of a website built on WordPress. Among other things, Jetpack provides the website operator with an overview of the site’s visitors. By displaying related posts and publications or offering the option to share content on the site, it is also possible to increase visitor numbers.

In addition, security features are integrated into Jetpack, so that a website using Jetpack is better protected against brute-force attacks. Jetpack also optimizes and speeds up the loading of images embedded on the website.

The operator of the Jetpack plugin for WordPress is Aut O’Mattic A8C Ireland Ltd., Business Centre, No. 1 Lower Mayor Street, International Financial Services Centre, Dublin 1, Ireland.

Jetpack sets a cookie on the data subject’s IT system. What cookies are has already been explained above. Each time a user visits one of the individual pages of this website—which is operated by the data controller and on which a Jetpack component has been integrated—the web browser on the data subject’s IT system is automatically prompted by the respective Jetpack component to transmit data to Automattic for analytical purposes. As part of this technical process, Automattic receives data that is subsequently used to generate an overview of website visits. The data obtained in this manner is used to analyze the behavior of the data subject who accessed the data controller’s website and is evaluated with the aim of optimizing the website. The data collected via the Jetpack component is not used to identify the data subject without first obtaining the data subject’s separate, explicit consent. The data is also made available to Quantcast.

Quantcast uses the data for the same purposes as Automattic.

As described above, the data subject may prevent our website from setting cookies at any time by adjusting the settings of the web browser being used, thereby permanently objecting to the setting of cookies. Such a setting in the user’s web browser would also prevent Automattic/Quantcast from setting a cookie on the data subject’s computer system. In addition, cookies already set by Automattic can be deleted at any time via the web browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by the Jetpack cookie-which relates to the use of this website—as well as the processing of this data by Automattic/Quantcast. To do so, the data subject must click the opt-out button at the link https://www.quantcast.com/opt-out/, which sets an opt-out cookie. The opt-out cookie set upon objection is stored on the data subject’s computer system. If the cookies are deleted from the data subject’s system after an objection has been raised, the data subject must access the link again and set a new opt-out cookie.

However, setting the opt-out cookie may result in the data subject no longer being able to fully use the data controller’s websites.

Automattic’s applicable privacy policy is available at https://automattic.com/privacy/. Quantcast’s applicable privacy policies are available at https:// andwww.quantcast.com/privacy/.

19. Privacy Policy Regarding the Use of LinkedIn The data controller has integrated components from LinkedIn Corporation into this website. LinkedIn is an internet-based social network that enables users to connect with existing business contacts and establish new business contacts. Over 400 million registered users use LinkedIn in more than 200 countries.

This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.

LinkedIn is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. For data protection matters outside the U.S., LinkedIn

Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Each time our website, which is equipped with a LinkedIn component (LinkedIn plug-in), is accessed, this component causes the browser used by the data subject to download a corresponding representation of the LinkedIn component. Further information on LinkedIn plug-ins is available at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn learns which specific subpage of our website the data subject is visiting.

If the data subject is logged into LinkedIn at the same time, LinkedIn recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the LinkedIn component and assigned by LinkedIn to the data subject’s respective LinkedIn account. If the data subject clicks a LinkedIn button integrated into our website, LinkedIn associates this information with the data subject’s personal LinkedIn user account and stores this personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website whenever the data subject is logged into LinkedIn at the same time as accessing our website; this occurs regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not wish for this information to be transmitted to LinkedIn, they can prevent the transmission by logging out of their LinkedIn account before visiting our website.

At https://www.linkedin.com/psettings/guest-controls, LinkedIn offers the option to opt out of email messages, text messages, and targeted ads, as well as to manage ad settings. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame, which may set cookies. You can opt out of these cookies at https://www.linkedin.com/legal/cookie- policy. LinkedIn’s current privacy policy is available at https://www.linkedin.com/legal/privacy-policy. LinkedIn’s cookie policy is available at

https://www.linkedin.com/legal/cookie-policy.

20. Privacy Policy Regarding the Use of Shariff The data controller has integrated the Shariff component into this website. The Shariff component provides social media buttons that comply with data protection regulations. Shariff was developed for the German computer magazine c’t and is published by GitHub, Inc.

The component’s developer is GitHub, Inc., 88 Colin P. Kelly Junior Street, San Francisco, CA 94107, USA.

Typically, the button solutions provided by social networks transmit personal data to the respective social network as soon as a user visits a website on which a social media button has been integrated. By using the Shariff component, personal data is transmitted to social networks only when a website visitor actively clicks one of the social media buttons. Further information on the Shariff component is available from the computer magazine c’t at http://www.heise.de/newsticker/meldung/Datenschutz-und- Social-Media-Der-c-t-Shariff-ist-im-Einsatz-2470103.html. The purpose of using the Shariff component is to protect the personal data of visitors to our website while simultaneously enabling us to integrate a social media button solution on this website.

Further information and GitHub’s applicable privacy policy can be found at https://help.github.com/articles/github- privacy-policy/.

21. Privacy Policy Regarding the Use of Twitter The data controller has integrated Twitter components into this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and share so-called tweets—short messages limited to 280 characters. These short messages are accessible to everyone, including people who are not registered with Twitter. However, the tweets are also displayed to the respective user’s so-called followers. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter enables users to reach a broad audience through hashtags, links, or retweets.

The operator of Twitter is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

Each time a user visits one of the individual pages of this website-which is operated by the data controller and on which a Twitter component (Twitter button) has been integrated-the Twitter component automatically prompts the web browser on the data subject’s computer system to download a representation of the corresponding Twitter component from Twitter. Further information about the Twitter buttons is available at

https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter learns which specific subpage of our website the data subject is visiting. The purpose of integrating the Twitter component is to enable our users to share the content of this website, to promote this website in the digital world, and to increase our visitor numbers.

If the data subject is logged into Twitter at the same time, Twitter recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and throughout the entire duration of their visit to our website. This information is collected by the Twitter component and assigned by Twitter to the data subject’s respective Twitter account. If the data subject clicks on one of the Twitter buttons integrated into our website, the data and information transmitted in this way are associated with the data subject’s personal Twitter user account and are stored and processed by Twitter.

Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged into Twitter at the time of accessing our website; this occurs regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not wish for this information to be transmitted to Twitter, they can prevent the transmission by logging out of their Twitter account before visiting our website.

Twitter’s current privacy policy is available at https://twitter.com/privacy?lang=de.

22. Privacy Policy Regarding the Use of YouTube The data controller has integrated YouTube components into this website. YouTube is an online video portal that allows video publishers to upload video clips free of charge and enables other users to view, rate, and comment on them, also free of charge.

YouTube allows the publication of all types of videos, which is why complete movies and TV shows, as well as music videos, trailers, and user-generated videos, are available via the internet portal.

YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Each time a user accesses one of the individual pages of this website-which is operated by the data controller and on which a YouTube component (YouTube video) has been integrated-the web browser on the data subject’s computer is automatically prompted by the respective YouTube component to download a representation of that YouTube component from YouTube. Further information about YouTube is available at

https://www.youtube.com/yt/about/de/. As part of this technical process, YouTube and Google learn which specific subpage of our website the data subject is visiting.

If the data subject is logged into YouTube at the same time, YouTube recognizes which specific subpage of our website the data subject is visiting when a subpage containing a YouTube video is accessed. This information is collected by YouTube and Google and associated with the data subject’s respective YouTube account.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website whenever the data subject is logged into YouTube at the same time as accessing our website; this occurs regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not wish for this information to be transmitted to YouTube and Google, they can prevent the transmission by logging out of their YouTube account before visiting our website.

The privacy policy published by YouTube, available at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing, and use of personal data by YouTube and Google.

23. Legal Basis for Processing Article 6(1)(a) of the GDPR serves as the legal basis for our company’s processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party—as is the case, for example, with processing operations required for the delivery of goods or the provision of other services or consideration— then the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the implementation of pre-contractual measures, such as in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data—such as to fulfill tax obligations-the processing is based on Article 6(1)(c) of the GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance information, or other vital information subsequently had to be disclosed to a doctor, a hospital, or other third parties. In such cases, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, provided that the processing is necessary to safeguard a legitimate interest of our company or a third party, unless the interests, fundamental rights, and fundamental freedoms of the data subject override such interests. We are permitted to carry out such processing operations in particular because they were specifically mentioned by the European legislator. In this regard, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 of the GDPR).

24. Legitimate interests in processing pursued by the controller or a third party If the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business operations for the benefit of all our employees and shareholders.

25. Period for which personal data is stored The criterion for the duration of personal data storage is the applicable statutory retention period. Upon expiration of this period, the relevant data is routinely deleted, provided it is no longer necessary for the performance of a contract or for entering into a contract.

26. Legal or contractual requirementsfor providing personal data; necessity for entering into a contract; obligation of the data subject to provide personal data; possible consequences of failure to provide data

We would like to inform you that the provision of personal data is in some cases required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information about the contracting party). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we must then process. For example, the data subject is obligated to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will explain to the data subject

on a case-by-case basis as to whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract; whether there is an obligation to provide the personal data; and what the consequences of failing to provide the personal data would be.

27. Existence of Automated Decision-Making As a responsible company, we do not engage in automated decision-making or profiling.

Developed by the legal tech specialists at Willing & Able, who also developed the system for the digital record of processing activities. 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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