Privacy Notice – Convenience Translation

Thank you very much for your interest in our company. Data protection has a very high priority for wundertax GmbH (hereinafter referred to as „wundertax GmbH“ or “we”). The processing of personal data, such as name, address, e-mail address or telephone number, is always carried out in accordance with the basic data protection regulations and in compliance with the country-specific data protection regulations applicable to us.

With this privacy policy we would like to inform you about the type, scope and purpose of the personal data collected, used and processed by us and about your right as a data subject.

Important note: This privacy notice is a convenient translation of the privacy policy on the website in German language. In case of doubt, the German language privacy policy will always apply: https://wundertax.de/datenschutz/

1. Introduction

In the following, we provide information about the collection of personal data when using

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is wundertax GmbH, Berliner Straße 80, 13189 Berlin, email: support@wundertax.com. We are legally represented by Daniel Hanemann.

Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).

If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access,
  • Right to correction or deletion,
  • Right to limit processing,
  • Right to object to the processing ,
  • Right to data transferability,
  • Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Making contact

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

We send newsletters with the tools

  • SendGrid of the provider Twilio, Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA (privacy policy: https://www.twilio.com/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the process in the USA.
  • Salesforce of the provider salesforce.com Germany GmbH, Erika-Mann-Straße 31-37, 80636 Munich (privacy policy: https://www.salesforce.com/company/privacy/). The provider processes content, usage, meta/communication data and contact data in the process in the EU.

3. Data processing on our website

3.1. Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

  • Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Telemedia Data Protection (Telekommunikation-Telemedien-Datenschutz-Gesetz, “TTDSG”).
  • Otherwise, this storage or access takes place on the basis of the website visitor’s consent (Section 25 para. 1 TTDSG).

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.3. Web hosting and provision of the website

Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxemburg, Luxemburg. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU and the USA. Further information can be found in the provider’s privacy policy at https://aws.amazon.com/privacy/.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

The legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We use the content delivery network Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at https://www.cloudflare.com/privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.4. Vacant positions

We publish positions that are vacant in our company on our website, on pages linked to the website or on third-party websites.

The processing of the data provided as part of the application is carried out for the purpose of implementing the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. GDPR in conjunction with Sec. 26 para. 1 of the German Data Protection Act (Bundesdatenschutzgesetz). We have marked the data required to carry out the application process accordingly or refer to them. If applicants do not provide this data, we cannot process the application. Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 para. 1 s. 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the resume or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process the applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 s. 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our data processors in the area of recruiting and to the employees otherwise involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we delete the data only after the employment relationship has ended. Otherwise, we delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures as well, we will not delete their data until one year after receiving the application.

3.5. Registration and preparation of tax returns

We help website visitors to prepare their tax returns. During the registration and preparation process, we process all data relevant to the preparation of a tax return, in particular:

  • First name/Surname
  • Age
  • E-mail address
  • Address
  • Telephone number
  • Date of birth
  • Marital status
  • Bank details
  • Tax number
  • Tax identification number
  • ther tax-relevant information that you provide in the tax return.

The processing of the data is carried out for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 p. 1 lit. b GDPR).

3.6 Transmission to financial authorities

The transmission of the collected data within the scope of the online tax return to the tax office responsible for you will only take place after your express consent in accordance with Art. 6 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future, e.g. by e-mail to the e-mail address given above. Please note that after the tax return has been transmitted to the tax authorities, the revocation can no longer have any effect.

Please also note the following additional data protection notice by the tax authorities:

“This software collects personal data within the meaning of Article 4 No. 1 of the General Data Protection Regulation (GDPR) and Article 9 (1) of the GDPR for the purpose of processing. In addition to the pure data required for tax assessment, the software collects data about the type of operating system of the user and transmits it to the tax authorities. This data is needed to ensure proper processing of the data and to prevent errors in the processing process. The data is used within the scope of Art. 6 Para. 1 Sentence 1 lit. e) in conjunction with. Abs. 3 Satz 1 lit. b) GDPR in conjunction with federal or state tax laws by the tax administration and only for the stated purpose.”

3.7 Processing of special categories of data

As part of the preparation of the online tax return, it is also necessary to collect and process special categories of personal data in accordance with Art. 9 GDPR. This concerns information on religious affiliation (e.g. with regard to a church tax liability), trade union affiliation and health.

The legal basis for the processing is the consent of the user (Art. 9 para. 2 lit. a GDPR). You can revoke your consent at any time with effect for the future, e.g. by sending an e-mail to the e-mail address given above. Please note that in these cases the tax return may not be sufficiently completed and no transmission to the tax authorities can take place. Moreover, after transmission to the tax authorities, the revocation of consent to data transmission can no longer have any effect with regard to the transmission.

3.8. Payment, dunning and collection service providers

3.8.1. Payment providers

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

  • GoCardless Ltd, Sutton Yard, 65 Goswell Road London, UK

  • Adyen N.V., Simon Carmiggeltstraat 6-50, 1011 DJ, Netherlands

3.8.2. Dunning and collection service providers

In the event of non-payment, we will pass on the following personal data to our collection partner:

  • First and last name
  • Postal address
  • Contact details (e-mail address, telephone number, if available)
  • Bank details (bank name, IBAN, BIC)

The partner is PAIR Finance GmbH, Hardenbergstraße 32, 10623 Berlin. The personal data listed above will be processed in the EU. In the commercial dunning phase, the partner acts as a processor, while in the collection process it acts as the data controller for the processing of the transmitted data.

The legal basis for the processing is Art. 6 (1) p. 1 lit. b GDPR, as the processing is necessary for the performance of a contract concluded with the user.

3.9 KYC procedure

Identification with a valid identification document is carried out via KYC procedure. After the registration process, you will be asked to complete a KYC procedure. The actual procedure itself is carried out by the provider Sum and Substance Ltd, 30 St. Mary Axe, London, England, EC3A 8BF on our behalf. The data you provide in the registration process is transmitted to Sum and Substance so that the provider can verify its accuracy via video-identification. The provider processes data in the EU.

A secure video connection is established between your mobile device and Sum and Substance. This requires Sum and Substance to temporarily allow access to your mobile phone camera and microphone. This enables the Sum and Substance employee to see you via your mobile phone camera, for example. In the following, your identification document, which you have to hold up to the camera, will be checked and compared with the data you provided during registration.

Photographs and, if necessary, video recordings of your identity document will be taken to prove that you have carried out the procedure. Particular attention will be paid to the integrity, authenticity and security features. You will also be asked to read out the number of your identity document. Parts of the interview will also be recorded and stored for this purpose.

In detail, the following personal data will be processed:

  • general personal data: first and last name, gender, personal identification code or number, date of birth, legal capacity, nationality and citizenship, location (street, city, country, postcode);
  • Identity document data: Type of document, issuing country, number, expiry date, MRZ, information embedded in the barcode of the document (may vary depending on the document), security features;
  • facial image data; photographs of the face (including selfie images) and photograph or scan of the face on the identity document, videos, sound recordings;
  • biometric data: Facial characteristics;
  • Bank details: Cardholder name, expiry date, first 6 and last 4 digits of card number, data from documents presented as proof of origin of money/assets;
  • Contact information: Address, email address, telephone number, IP address;
  • technical data: Information on date, time and activity in the services; IP address and domain name; software and hardware attributes (camera name and type); general geographical location (e.g. city, country) from the data subject’s device;
  • unique identifier (Applicant ID) created only to link the data subject and their personal data within the information system;
  • Relevant publicly available data: Information about a person who is a Politically Exposed Person (PEP) or on sanctions lists;
  • personal data additionally provided by data subjects, such as data obtained during their communications with the processor (e.g. requests, reports).

3.9.1 Provider

Sum and Substance Ltd, 30 St. Mary Axe, London, England, EC3A 8BF, United Kingdom.

The legal basis for the processing is consent pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) DSGVO. Consent can be revoked at any time with effect for the future, e.g. by e-mail to the above address.

3.9.3 Privacy policy

Further information can be found in the privacy policy of Sum and Substance: https://sumsub.com/privacy-notice-service/.

3.10. Third parties

3.10.1. ​Google Places API​

We use Google Places API for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=en.

3.10.2. ​Criteo​

We use Criteo for advertisement. The provider is Criteo SA, 32 rue Blanche, 75009 Paris, France. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data is stored for a maximum of 13 months from the date of collection. Further information is available in the provider’s privacy policy at https://www.criteo.com/privacy/.

3.10.3. ​AppsFlyer​

We use AppsFlyer for analytics. The provider is AppsFlyer Ltd., 14 Maskit st. Herziliya, Israel. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.appsflyer.com/legal/privacy-policy/.

3.10.4. ​Microsoft Clarity​

We use Microsoft Clarity for analytics and to identify opportunities from our website visitors. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://privacy.microsoft.com/de-de/privacystatement.

3.10.5. ​Auth0​

We use Auth0 to manage authentifications. The provider is Auth0, Inc., 10900 NE 8th Street, Suite 700, Bellevue, WA 98004, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in sufficiently authenticating users of our applications.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://auth0.com/privacy.

3.10.6. ​Datadog​

We use Datadog to monitor applications, to track errors in applications or on websites, and for log management. The provider is Datadog, Inc., 620 8th Ave, 45th Floor, New York, NY 10018 USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in being able to quickly find the errors in our applications.

The data will be archived when the purpose of its collection has ceased to exist. All customer data archived in backups are stored separately and excluded from any further processing, unless required by law. Further information is available in the provider’s privacy policy at https://www.datadoghq.com/legal/privacy/#sharing-of-information.

3.10.7. ​Facebook Custom Audiences​

We use Facebook Custom Audiences for advertisement. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://www.facebook.com/policy.php.

3.10.8. ​Microsoft Advertising​

We use Microsoft Advertising for analytics and for conversion tracking. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://privacy.microsoft.com/en-gb/privacystatement.

3.10.9. ​metabase​

We use metabase for analytics. The provider is Metabase Inc., 660 4th Street #557, San Francisco, CA 94107, USA. The provider processes contact data (e.g. e-mail addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

Further information is available in the provider’s privacy policy at https://www.metabase.com/privacy/.

3.10.10. ​Google Marketing Platform​

We use Google Marketing Platform for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=en-US.

3.10.11. ​Google Tag Manager​

We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=en-US.

3.10.12. ​Twitter Conversion Tag​

We use Twitter Conversion Tag for conversion tracking. The provider is Twitter International Company, 26 Fenian St, Dublin, D02 FX09, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://twitter.com/en/privacy.

3.10.13. ​Snap Pixel​

We use Snap Pixel for analytics. The provider is Snap Group Limited, 7-11 Lexington Street, London W1F 9AF, Great Britain. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.snap.com/en-GB/privacy/privacy-policy.

3.10.14. ​Google Conversion Tag​

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=en https://support.google.com/tagmanager/answer/9323295?hl=en&ref_topic=3441532.

3.10.15. ​Facebook Conversion API​

We use Facebook Conversion API for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.facebook.com/policy.php.

3.10.16. ​TikTok Pixel​

We use TikTok Pixel for analytics and for advertisement. The provider is TikTok, Inc., 10100 Venice Blvd Suite 401 Culver City, CA 90232, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://ads.tiktok.com/i18n/official/policy/privacy.

3.10.17. ​Outbrain​

We use Outbrain for advertisement. The provider is Outbrain Inc., 222 Broadway 19th Floor, New York, NY 10038, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.outbrain.com/legal/privacy#privacy-policy.

3.10.18. ​Pinterest Conversion Tag​

We use Pinterest Conversion Tag for conversion tracking. The provider is Pinterest Inc., 505 Brannan Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. e-mail addresses, telephone numbers), and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://policy.pinterest.com/en/privacy-policy.

3.10.19. ​wordpress.com​

We use wordpress.com to create websites. The provider is Aut O’Mattic A8C Ireland Ltd., 25 Herbert Pl, Dublin, D02 AY86, Ireland. The provider processes contact data (e.g. e-mail addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses), and master data (e.g. names, addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://automattic.com/privacy/.

3.10.20. ​Cloudflare​

We use Cloudflare for application security. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in increasing the security of our app by preventing malicious traffic from reaching our server.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.cloudflare.com/en-gb/privacypolicy/.

3.10.21. ​Google Analytics​

We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://policies.google.com/privacy?hl=en-US.

3.10.22. ​Typeform​

We use Typeform for quizzes and forms. The provider is Typeform S.L., 163 Carrer de Bac de Roda, Barcelona, Spain. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://admin.typeform.com/to/dwk6gt.

3.10.23. ​OneTrust​

We use OneTrust to manage consents. The provider is OneTrust Technology Limited, Atlanta, GA, 1200 Abernathy Rd NE, Building 600, Atlanta, GA 30328, USA. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. c DSGVO. The processing is necessary for the fulfillment of a legal obligation to which we are subject.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://www.onetrust.com/privacy-notice/.

3.10.24. Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

The purpose of reCAPTCHA is to verify whether data entry on our websites (e.g. in a contact form) is made by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent by the website visitor on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The data processing is based on Art. 6 para. 1 s. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offerings from improper automated spying or improper use.

Further information on Google reCAPTCHA as well as Google’s privacy policy can be found here: https://policies.google.com/privacy?hl=de and https://www.google.com/recaptcha/intro/android.html.

4. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

4.1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads. We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

4.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.3. Snapchat

We maintain a profile on Snapchat. The operator is Snap Inc, 3000 31st Street, Santa Monica, California 90405, USA. The privacy policy is available here: https://snap.com/de-DE/privacy/privacy-policy.

4.4. Tiktok

We maintain a profile on Tiktok. The operator is musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA. The privacy policy is available here: https://www.tiktok.com/de/privacy-policy.

4.5. Pinterest

We maintain a profile on Pinterest. The operator is Pinterest Inc, 635 High Street, Palo Alto, CA, 94301, USA. The privacy policy is available here: https://about.pinterest.com/de/privacy-policy. One way to object to data processing is via the settings for advertisements: https://about.pinterest.com/de/privacy-policy.

4.6. YouTube

We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.

4.7. Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. One way to object to data processing is via the settings for advertisements: https://twitter.com/personalization.

4.8. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.