We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of 28Apps Software GmbH. The use of the Internet pages of 28Apps Software GmbH is possible without providing any personal data. However, if a data subject wishes to use special 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 consent of the data subject.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to 28Apps Software GmbH. Through this privacy policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights through this privacy policy.

28Apps Software GmbH has implemented numerous technical and organizational measures as the data controller to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions may have security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, such as by telephone.

1. Definitions

The privacy policy of 28Apps Software GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for both the public and our customers and business partners. To ensure this, we would like to first explain the terminology used.

We use, among others, the following terms in this privacy policy:

a) Personal Data
Personal data refers to any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Data Subject
A data subject is any identified or identifiable natural person whose personal data is processed by the data controller.

c) Processing
Processing refers to 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, alignment, or combination, restriction, erasure, or destruction.

d) Restriction of Processing
Restriction of processing is the marking of stored personal data to limit its future processing.

e) Profiling
Profiling refers to any form of automated processing of personal data intended 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 to ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or Data Controller
The controller or data 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided by Union or Member State law.

h) Processor
A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i) Recipient
A recipient is a natural or legal person, public authority, agency, or another body, to which personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the context of a particular investigation in accordance with Union or Member State law are not considered recipients.

j) Third Party
A third party is a natural or legal person, public authority, agency, or another body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent
Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Name and Address of the Data Controller

The controller for the purposes of the GDPR, other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is:

28Apps Software GmbH
Martinistraße 43
28195 Bremen
Germany
Tel.: 0421/301 59 900
Email: kontakt@28apps.de
Website: www.28apps.de

3. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Andreas Bethke
B³ Datenschutz GmbH
Papenbergallee 34
25548 Kellinghusen
Germany
Tel.: 0421/301 59 900
Email: ext-dsb@b3-datenschutz.de

Data subjects can contact our Data Protection Officer directly with any questions and suggestions regarding data protection.

4. Cookies

The website of 28Apps Software GmbH uses cookies. Cookies are text files that are stored in a computer system via an Internet browser.

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

Through the use of cookies, 28Apps Software GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

Cookies allow us, as mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, the user of a website that uses cookies does not need to enter their login details every time they visit the website, as this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart through a cookie.

The data subject can prevent the setting of cookies through our website at any time by adjusting the settings of the Internet browser used, thereby permanently rejecting the setting of cookies. Additionally, cookies that have already been set can be deleted at any time through an Internet browser or other software programs. This is possible in all commonly used Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

5. Google Ajax & jQuery Libraries, Google Web Fonts

This website uses Ajax and jQuery technologies. It is pointed out that by using Google Web Fonts, an external server of Google in the USA is accessed when this site is visited. Whether Google logs such server requests and how these are used is unknown to us. However, we assume that Google’s privacy policy applies in this regard as well. It is highly likely that your IP address will be stored for several months. The same applies to JavaScript elements that are loaded from Google servers for browser compatibility purposes (e.g., with IE9).

6. Collection of General Data and Information

The website of 28Apps Software GmbH collects a series of general data and information each time a data subject or an automated system accesses the website. This general data and information are stored in the server log files. The collected information may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system arrives at our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information that may be used in the event of attacks on our IT systems.

When using this general data and information, 28Apps Software GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website as well as the advertising for it, (3) ensure the continued functionality of our IT systems and the technology of our website, and (4) provide law enforcement authorities with the necessary information for prosecution in case of a cyberattack. Therefore, 28Apps Software GmbH analyzes anonymously collected data and information statistically, with the aim of increasing data protection and data security in our company and ensuring an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.

7. Contact Options via the Website
The website of 28Apps Software GmbH contains information required by law that enables quick electronic contact with our company, including a general address for electronic mail (email address). If a data subject contacts the data controller via email or through a contact form, the personal data transmitted by the data subject will be automatically stored. The stored data includes the user’s email address and name. Such personal data voluntarily submitted by a data subject to 28Apps Software GmbH will be stored for the purpose of processing or contacting the data subject. If the inquiry does not lead to a business relationship, the data will be deleted from the mail server of 28Apps Software GmbH within one month. No transfer of this personal data to third parties will take place.

8. Comment Function on the Blog on the Website
28Apps Software GmbH refrains from enabling the comment function on the blog for data protection reasons, thus adhering to the principle of data minimization.

9. Routine Deletion and Blocking of Personal Data
The data controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose, or as provided by the European legislator or another legislator in laws or regulations to which the data controller is subject.
If the storage purpose ceases to exist or a storage period prescribed by the European legislator or another competent legislator expires, personal data will routinely be blocked or deleted in accordance with legal regulations.

10. Rights of the Data Subject
a) Right to Confirmation
Every data subject has the right granted by the European legislator 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 of confirmation, they may contact an employee of the data controller at any time.

b) Right to Access
Every data subject whose personal data is processed has the right granted by the European legislator to obtain, at any time and free of charge, information from the data controller about the personal data stored concerning them and a copy of this information. Furthermore, the European legislator grants the data subject the right to be informed about the following information:

  • the purposes of processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data has been disclosed or will be disclosed, especially in the case of recipients in third countries or international organizations
  • if possible, the planned duration for which the personal data will be stored or, if not possible, the criteria for determining this duration
  • the existence of the right to rectification or erasure of personal data concerning them or to the restriction of processing 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 has not been collected from the data subject: all available information about the source of the data
  • the existence of automated decision-making, including profiling, as per Article 22(1) and (4) GDPR, and — at least in these cases — meaningful information about the logic involved, as well as the significance and the intended consequences of such processing for the data subject

Furthermore, the data subject has the right to know whether personal data has been transferred to a third country or an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards related to the transfer.
If a data subject wishes to exercise this right of access, they may contact an employee of the data controller at any time.

c) Right to Rectification
Every data subject has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request, taking into account the purposes of processing, the completion of incomplete personal data — including by means of a supplementary statement.
If a data subject wishes to exercise this right to rectification, they may contact an employee of the data controller at any time.

d) Right to Erasure (Right to be Forgotten)
Every data subject has the right granted by the European legislator to request from the controller the immediate erasure of personal data concerning them, provided that one of the following reasons applies, and insofar as the processing is not necessary:

  • The personal data has been collected or otherwise processed for purposes that are no longer necessary.
  • The data subject withdraws their consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing according to Article 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects according to Article 21(2) GDPR.
  • The personal data has been processed unlawfully.
  • The erasure of personal data is necessary for compliance with a legal obligation under Union law or the law of the member states to which the controller is subject.
  • The personal data has been collected in relation to the offer of information society services according to Article 8(1) GDPR.

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by 28Apps Software GmbH, they may contact an employee of the data controller at any time. The employee of 28Apps Software GmbH will ensure that the erasure request is complied with immediately.
If the personal data has been made public by 28Apps Software GmbH and our company is obliged to erase the personal data as the controller according to Article 17(1) GDPR, 28Apps Software GmbH will take reasonable measures, also of a technical nature, to inform other controllers processing the published personal data that the data subject has requested the erasure of all links to this personal data or of copies or replications of this personal data, insofar as the processing is not necessary. The employee of 28Apps Software GmbH will take the necessary steps in individual cases.

e) Right to Restrict Processing
Every data subject has the right granted by the European legislator to request the restriction of processing from the controller if one of the following conditions is met:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
  • The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defense of legal claims.
  • The data subject has objected to processing according to Article 21(1) GDPR, and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by 28Apps Software GmbH, they may contact an employee of the data controller at any time. The employee of 28Apps Software GmbH will initiate the restriction of processing.

f) Right to Data Portability
Every data subject has the right granted by the European legislator 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 those data to another controller without hindrance from the controller to whom the personal data has been provided, provided that the processing is based on consent according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract according to Article 6(1)(b) GDPR and the processing is carried out by automated means, unless the processing is 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 under Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible, without adversely affecting the rights and freedoms of others.
To assert the right to data portability, the data subject may contact an employee of 28Apps Software GmbH at any time.

g) Right to Object
Every data subject 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, which is based on Article 6(1)(e) or (f) GDPR. This applies also to profiling based on these provisions.
In the event of an objection, 28Apps Software GmbH 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 for the establishment, exercise, or defense of legal claims.
If 28Apps Software GmbH processes personal data for the purpose of direct marketing, the data subject has the right at any time to object 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 28Apps Software GmbH to the processing for the purposes of direct marketing, 28Apps Software GmbH will no longer process the personal data for these purposes.

The data subject also has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them, which is carried out by 28Apps Software GmbH for scientific or historical research purposes or for statistical purposes according to Article 89(1) 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 employee of 28Apps Software GmbH directly or any other employee.

h) Automated Decisions in Individual Cases, Including Profiling
Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided that the decision is not necessary for entering into, or the performance of, a contract between the data subject and the data controller, or is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or is based on the data subject’s explicit consent.
If the data subject wishes to exercise the rights concerning automated decisions, they may contact an employee of the data controller at any time.

i) Right to Withdraw Consent under Data Protection Law
Every data subject has the right granted by the European legislator to withdraw their consent to the processing of personal data at any time. If the data subject wishes to withdraw their consent, they may contact an employee of the data controller at any time.

11. Data Protection Provisions about the Application and Use of Google Analytics (with Anonymization Function)
On this website, the data controller has integrated the component of Google Analytics (with the anonymization function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analytics service collects, among other things, data about the website from which a data subject has come (the so-called referrer), which subpages of the website were accessed, and how often and for what duration a subpage was viewed. Web analytics is mainly used for optimizing a website and for cost-benefit analysis of Internet advertising.
The data controller uses the addition “_gat._anonymizeIp” for the web analytics through Google Analytics. This addition causes Google Analytics to shorten and anonymize the IP address of the data subject’s Internet connection if the access to our websites occurs from a member state of the European Union or from another contracting state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the collected data and information to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services concerning the use of our website. Google Analytics uses cookies. Cookies are text files that are stored in the Internet browser on a computer system. When a user accesses the website, a cookie is stored on the user’s operating system. Each time the user accesses the website, the data subject’s personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google. These personal data are stored by Google in the United States.
Google may share these personal data collected through the technical process with third parties.
The data subject can prevent the installation of cookies through our website at any time by means of a corresponding adjustment of the Internet browser used, and thus permanently deny the installation of cookies. Such an adjustment of the Internet browser used would also prevent Google from placing a cookie on the data subject’s information technology system. Furthermore, cookies already in use by Google Analytics can be deleted at any time via the Internet browser or other software programs.
Furthermore, the data subject has the possibility to object to the collection of data generated by Google Analytics related to the use of this website and to the processing of this data by Google and can prevent such. To do this, the data subject must download a browser add-on from the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on informs Google Analytics via JavaScript that no data and information about the visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered a contradiction by Google. If the data subject’s information technology system is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to disable Google Analytics.
Further information and the applicable data protection provisions of Google can be retrieved under https://www.google.com/analytics/terms/us.html and https://www.google.com/policies/privacy/.

12. Data Protection Provisions about the Application and Use of Facebook
On this website, the data controller has integrated components of Facebook. Facebook is a social network. A social network is a social meeting point operated on the Internet, an online community that generally allows users to interact with each other and communicate in a virtual space. A social network may serve as a platform for sharing opinions and experiences, or it may enable the Internet community to provide personal or business-related information.
Facebook allows social network users to create a personal profile, upload pictures, and connect via friend requests. If a user registers on Facebook, the data collected during this process is used by Facebook for its own purposes.
If the data subject accesses any of the individual pages of this website operated by the data controller and has integrated a Facebook component (Facebook plugin), the Internet browser on the data subject’s information technology system is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook.
As part of this technical procedure, Facebook receives information about which specific subpage of our website is visited by the data subject.
If the data subject is logged into Facebook at the same time, Facebook recognizes which specific page is visited by the data subject and assigns this information to the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, such as the “Like” button, or if the data subject submits a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.
Facebook receives via the Facebook component information that the data subject has visited our website, provided that the data subject is logged into Facebook at the same time as they access our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want such transmission of this information to Facebook, they can prevent it by logging out of their Facebook account before accessing our website.
The data protection provisions published by Facebook, which are available at https://facebook.com/about/privacy/, provide information about the collection, processing, and use of personal data by Facebook. Furthermore, it is explained there which setting options Facebook offers to protect the privacy of the data subject.

17. Data Protection Provisions Regarding the Use and Application of Google Analytics
This website uses the service “Google Analytics,” which is offered by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), to analyze the usage of the website by users.

During your visit to the website, the following data is recorded, among others:

  • Visited pages
  • Achievement of “website goals” (e.g., contact inquiries and newsletter registrations)
  • Your behavior on the pages (e.g., clicks, scroll behavior, and duration of stay)
  • Your approximate location (country and city)
  • Your IP address (anonymized, so that no unique identification is possible)
  • Technical information such as browser, internet provider, device, and screen resolution
  • Source of your visit (i.e., which website or advertising medium you came from)

The service also uses “cookies”—text files that are stored on your device. The information collected through cookies is generally sent to a Google server in the USA and stored there. This website employs IP anonymization. The user’s IP address is shortened within the member states of the EU and the European Economic Area. This shortening eliminates the personal reference of your IP address. In accordance with the data processing agreement that the website operators have concluded with Google Inc., this service creates an evaluation of website usage and activity based on the collected information and provides services related to internet usage.

The processing of “Analytics Cookies” is based on Art. 6 para. 1 lit. a) GDPR, thus exclusively with your consent. Consent can be revoked at any time via the cookie consent management tool.

You have the option to prevent the storage of cookies on your device by making the appropriate settings in your browser. It is not guaranteed that you will be able to access all functions of this website without restrictions if your browser does not allow cookies.

Furthermore, you can prevent the collection of data generated by cookies (including your IP address) from being sent to Google Inc. and used by Google Inc. by using a browser plugin. The following link leads you to the corresponding plugin: https://tools.google.com/dlpage/gaoptout?hl=en. Here you can find more information about the data usage by Google Inc.: https://support.google.com/analytics/answer/6004245?hl=en.

18. Data Protection Provisions Regarding the Use and Application of HubSpot
We use the service “HubSpot” on this website for marketing purposes. HubSpot is a management service for user databases. We use HubSpot on this website for our online marketing activities.

The service is provided by HubSpot Inc, 25 First Street, Cambridge, MA 02141, USA. Contact: hubspotgermany@hubspot.com; Tel. +1 888 482 7768.

Marketing purposes include email marketing, social media marketing, and contact management.

During your visit to the website, the following data is recorded, among others:

  • Geographical location
  • Browser type
  • Navigation information
  • Referring URL
  • Performance data
  • Information about how often the application is used
  • Mobile app data
  • Login credentials for the HubSpot subscription service
  • Files displayed on-site
  • Domain names
  • Viewed pages
  • Aggregated usage
  • Operating system version
  • Internet service provider
  • IP address
  • Device ID
  • Duration of visit
  • Source of application download
  • Operating system
  • Events that occur within the application
  • Access times
  • Clickstream data
  • Device model and version

The service also uses “cookies”—text files that are stored on your device. The information collected through cookies is sent to the USA and stored there.

The processing of “Cookies” is based on Art. 6 para. 1 lit. a) GDPR, thus exclusively with your consent. Consent can be revoked at any time via the cookie consent management tool.

The fundamental use of the service is based on our legitimate interest according to Art. 6 para. 1 lit. f) GDPR, whereby our interest serves to improve our external presentation.

We have concluded a data processing agreement with HubSpot regarding the processing of your data. The agreement includes, among other things, a list of subcontractors, as well as the standard contractual clauses. Further information can be found at https://legal.hubspot.com/de/dpa.

19. Data Protection Provisions Regarding the Use and Application of TidioChat
We use the chat platform “Tidio” on our website for support purposes. Messages and exchanged data are stored within the Tidio application.

The platform is operated by Tidio LLC, 180 Steuart St. CA 94119, San Francisco, USA, and Tidio Poland Sp. z o.o., Wojska Polskiego 81, 70-481 Szczecin, Poland.

The recorded messages or data are only processed to handle user inquiries.

The use of the platform is based on our legitimate interest according to Art. 6 para. 1 lit. f) GDPR, whereby our interest serves to improve customer communication.

Cookies are not used in connection with the service.

We have concluded a data processing agreement with the European subsidiary Tidio Poland Sp. z o.o. according to Art. 28.

Further information on data protection at Tidio can be found at https://www.tidio.com/privacy-policy/.

20. Legal Basis for Processing
Art. 6 para. 1 lit. a GDPR serves our company as the legal basis for 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, such as in processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 para. 1 lit. b GDPR. The same applies to processing operations necessary for the performance of pre-contractual measures, for example, 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 for the fulfillment of tax obligations, the processing is based on Art. 6 para. 1 lit. c GDPR. In rare cases, processing personal data may be necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor is injured in our company and their name, age, health insurance data, or other vital information would have to be disclosed to a doctor, hospital, or other third parties. In that case, the processing would be based on Art. 6 para. 1 lit. d GDPR.
Ultimately, processing operations may be based on Art. 6 para. 1 lit. f GDPR. This legal basis applies to processing operations that are not covered by any of the aforementioned legal bases, if the processing is necessary to protect the legitimate interests of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not override those interests. Such processing operations are permitted for us, especially because they were specifically mentioned by the European legislator. He assumed that a legitimate interest could be assumed if the data subject is a customer of the data controller (Recital 47 Sentence 2 GDPR).

21. Legitimate Interests in Processing Pursued by the Controller or a Third Party
If the processing of personal data is based on Article 6 para. 1 lit. f GDPR, our legitimate interest is to conduct our business activities for the benefit of all our employees and our shareholders.

22. Duration for Which Personal Data Will Be Stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After the retention period has expired, the relevant data is routinely deleted, provided that it is no longer required for the fulfillment of the contract or the initiation of a contract.

23. Legal or Contractual Provisions for Providing Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Non-Disclosure
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual arrangements (e.g., information about the contractual partner).
In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which must then be processed by us. The data subject is, for example, obliged to provide us with personal data if our company concludes a contract with them. A non-provision of personal data would result in the fact that the contract with the data subject could not be concluded.
Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is legally or contractually required or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences non-provision of the personal data would have.

24. Hotjar
We use Hotjar from Hotjar Limited (Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta) on our website to statistically analyze visitor data. Hotjar is a service that analyzes your behavior and feedback as a user on our website through a combination of analysis and feedback tools. We receive reports and visual representations from Hotjar that show us where and how you move on our page. Personal data is automatically anonymized or deleted after the usage data has been evaluated. We can evaluate usage data but not identify users. You can find further information about Hotjar and how it uses data at https://www.hotjar.com/legal/policies/privacy/.