Data protection

This privacy policy applies to the website (hurra.com) of Hurra Communications GmbH.

For users from Poland, the data protection conditions of Hurra Communications Sp. z o.o. apply at https://www.hurra.com/pl/polityka-prywatnosci/.

Our privacy policy for our technologies and our online web analysis and web controlling system OwaPro can be found here: https://privacy.hurra.com/.

With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as “data” for short) we process for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). The terms used are not gender-specific.

Table of contents

  • initiation
  • person responsible
  • Contact data protection officer
  • Overview of processing
  • Relevant legal bases
  • Safety measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Business services
  • Provision of online services and web hosting
  • Using Google API Services and Google OAuth
  • Contact and request management
  • Communication via messenger
  • Video conferences, online meetings, webinars, and screen sharing
  • application process
  • cloud services
  • Newsletters and electronic notifications
  • Promotional communication via e-mail, post, fax or telephone
  • Web analysis, monitoring and optimization
  • online marketing
  • Presences on social networks (social media)
  • Plug-ins and embedded features and content
  • Management, organization and auxiliary tools
  • Amendment and update of the privacy policy
  • Rights of data subjects

Person responsible

Hurra Communications GmbH
Lautenschlagerstrasse 23a
70173 Stuttgart
germany
Authorized representatives: René Schweier, CEO
email: info@hurra.com


Contact data protection officer

Michael Bätge
data protection officer
Hurra Communications GmbH
Lautenschlagerstrasse 23a
70173 Stuttgart
germany

email: datenschutz@hurra.com

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Overview of processing

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

Types of data processed

  • inventory data.
  • payment details.
  • contact details.
  • Content data.
  • Contract data.
  • usage data.
  • Meta/communication data.
  • Applicant data.
  • Image and/or video recordings.
  • contact information (Facebook).


Categories of affected persons

  • customers.
  • employees.
  • interested parties.
  • communication partner.
  • user.
  • Applicant.
  • Business and contract partners.
  • Purposes of processing
  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • direct marketing.
  • Range measurement.
  • Tracking.
  • Office and organizational procedures.
  • Remarketing.
  • Conversion measurement.
  • Click tracking.
  • A/B testing.
  • Managing and responding to inquiries.
  • application process.
  • Content Delivery Network (CDN).
  • feedback.
  • Heat maps.
  • marketing.
  • Profiles with user-related information.
  • Target group building.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.


Relevant legal bases

The following is an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or place of residence. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or to carry out pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 (1) (c) GDPR) - Processing is necessary to fulfill a legal obligation to which the person responsible is subject.
  • Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act — BDSG). In particular, the BDSG contains special rules on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. It also regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.

Safety measures

In accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk. The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, availability and separation of data relating to it. We have also set up procedures that ensure the exercise of data subject rights, the deletion of data and responses to the data being compromised. In addition, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through privacy-friendly default settings. SSL encryption (https): In order to protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https://in the address bar of your browser.

Transfer of personal data

As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data. Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer is made for administrative purposes, the transfer of data is based on our legitimate entrepreneurial and business interests or takes place where it is necessary to fulfill our contract-related obligations or if the data subject has the consent of the person concerned or a legal permission.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or processing takes place as part of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with legal requirements.
Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses issued by the EU Commission, if certifications or binding internal data protection regulations exist (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

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Deletion of data

The data processed by us will be deleted in accordance with legal requirements as soon as their consent permitted for processing is withdrawn or other permits no longer apply (e.g. if the purpose of processing this data has ceased to apply or they are not necessary for the purpose). Unless the data is deleted because it is necessary for other and legally permitted purposes, its processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. As part of our data protection policy, we can provide users with further information about the deletion and storage of data that applies specifically to the respective processing process.

Use of cookies

Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, shopping cart content in an e-shop, the content accessed or functions used on an online offer. Cookies can also be used for various purposes, e.g. for the purpose of the functionality, security and convenience of online offerings and the preparation of analyses of visitor flows.

Information on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent is clearly communicated to users and contains information on the respective use of cookies.

Information on legal bases of data protection law: The legal basis on which data protection law we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in operating our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing processes.

Storage period: With regard to storage time, the following types of cookies are differentiated:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
  • Persistent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. User data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.


General information on revocation and objection (opt-out): Users can withdraw their consent at any time and also object to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (which may also limit the functionality of our online services). You can also object to the use of cookies for online marketing purposes via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.


Further information on processing processes, procedures and services:

  • Processing of cookie data based on consent:
    We use a cookie consent management process, in which user consents to the use of cookies, or the processing and providers mentioned as part of the cookie consent management process, can be obtained and managed and withdrawn by users. The declaration of consent is saved so that you do not have to repeat the request again and to be able to prove your consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The period of storage of consent may be up to two years. A pseudonymous user identifier is created and stored at the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and device used.
  • Consentmanager: cookie consent management; Service provider: Jaohawi AB, Håltegelvägen 1b, 72348 Västerås, Sweden; Site: https://www.consentmanager.de/; Privacy statement: https://www.consentmanager.net/; Order processing contract: https://www.consentmanager.net/tac.php; More information: The following data is stored on the service provider's servers in the EU: identification number (for the user, his browser, operating system and the device used), IP address, date and time, country, language, type, scope and purpose of consent, cookie settings of the browser, website on which the consent was given, technical information about the browser and operating system.

Business services

We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships and related measures and as part of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations. In particular, this includes obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other performance problems. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and corporate organization. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as in security measures to protect our contractual partners and our business operations from misuse, jeopardising of their data, secrets, information and rights (e.g. to involve telecommunications, transport and other assistance services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent necessary for the above purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.

We inform the contractual partners which data is required for the above purposes before or as part of data collection, e.g. in online forms, through special identification (e.g. colors) or symbols (e.g. asterisks, etc.), or personally.

We delete the data after expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for archiving legal reasons. The statutory retention period is ten years for tax-relevant documents as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions and other organizational documents and accounting documents required to understand these documents and six years for commercial and business letters received. The period begins at the end of the calendar year in which the last entry in the book was made, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent or the accounting document was created, the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between users and providers.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject of contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: interested parties; business and contract partners.
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; office and organizational procedures; administration and response to inquiries; conversion measurement (measurement of the effectiveness of marketing measures).
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. b) GDPR); legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Agency services: We process our clients' data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; legal bases: contract fulfilment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
  • Consulting: We process the data of our clients, clients and interested parties and other clients or contract partners (uniformly referred to as “clients) in order to be able to provide them with our consulting services. The processed data, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. If it is necessary for our contract performance, to protect vital interests or by law, or if there is consent from the clients, we disclose or transfer the clients' data to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services; legal bases: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
  • Offering software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to be able to further develop it. The required information is marked as such in the context of the conclusion of an order, order or comparable contract and includes the information required for service provision and billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfilment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
  • Brokerage services: We process the information provided by interested parties as part of the placement request for the purpose of establishing, executing and, if necessary, terminating a contract to arrange offers from providers of the products or services they have requested. We use the contact details of interested parties to specify their request via the agreed or otherwise permitted communication channel (e.g. telephone or e-mail) and to suggest suitable providers or offers to them on the basis of the specified request. In addition, we can ask interested parties questions about the success of our placement service at a later date, in accordance with legal requirements. We process the data of interested parties as well as the providers to fulfill our contractual obligations, to link the request from the interested parties submitted to us with the offers from the providers that suit them and forward them to appropriate providers, or to suggest the providers. We can log the entries in the online form sent by interested parties in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with legal accountability obligations (Article 5 (2) GDPR). This information is stored for a period of three to four years if we need to prove the original request (e.g. to be able to prove the right to contact the interested party); legal basis: contract fulfilment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).

Provision of online services and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage and database services, as well as security services and technical maintenance services.

The data processed as part of providing the hosting service may include all information relating to users of our online offer that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offers to browsers, and all entries made within our online offering or from websites.

  • Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and usability; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.); content delivery network (CDN).
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).


Further information on processing processes, procedures and services:

  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data about every access to the server (so-called server log files). The server log files may include the address and name of the retrieved websites and files, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used, on the one hand, for security purposes, e.g. to avoid server overloading (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server load and stability; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
  • Content delivery network: We use a “content delivery network” (CDN). A CDN is a service that allows content from an online offering, in particular large media files, such as graphics or program scripts, to be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
  • Cloudflare: content delivery network (CDN) - service that allows content from an online offering, in particular large media files, such as graphics or program scripts, to be delivered faster and more securely using regionally distributed servers connected via the Internet; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, United States; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.cloudflare.com; Privacy statement: https://www.cloudflare.com/privacypolicy/; Order processing contract: https://www.cloudflare.com/cloudflare-customer-dpa; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://www.cloudflare.com/cloudflare-customer-scc.

Contact and request management

When contacting us (e.g. via contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons will be processed insofar as this is necessary to answer the contact requests and any requested measures. Contact requests are answered and contact and inquiry data are managed within the framework of contractual or pre-contractual relationships to fulfill our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of legitimate interests in answering inquiries and maintaining user or business relationships.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: communication partner.
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; administration and response to inquiries; feedback (e.g. collecting feedback via online form); provision of our online offer and usability.
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).


Further information on processing processes, procedures and services:

  • contact form: If users contact us via our contact form, e-mail or other means of communication, we process the data provided to us in this context to process the submitted request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary to fulfill them and otherwise on the basis of our legitimate interests and the interests of the communication partners in answering the concerns and our legal storage obligations; legal bases: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
  • HubSpot: Software for customer administration, process and sales support (multi-channel communication, i.e. management of customer inquiries from various channels, sales, process management, analyses, feedback and survey functions); service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; legal bases: contract fulfilment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR), legitimate interests (Art. 6 para. 1 p. b) GDPR). 1 p. 1 lit. f) GDPR); Site: https://www.hubspot.de; Privacy statement: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://legal.hubspot.com/dpa.
  • Heyflow: We use heyflow.app to provide process and sales support for our products and services; Service provider: Heyflow GmbH, Jungfernstieg 49, 20354 Hamburg, Germany; Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Site: https://heyflow.app; Privacy statement: https://heyflow.app/de/datenschutz.


Communication via messenger

We use messengers for communication purposes and therefore ask you to follow the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection. You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer. In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of the messengers with activated encryption to ensure that the message content is encrypted. However, we would also like to point out to our communication partners that although the messenger providers do not view the content, they can find out that and when communication partners communicate with us and, depending on the settings of their device, also location information (so-called metadata) are processed.

Information on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. In addition, unless we ask for consent and, for example, you contact us on your own initiative, we use Messenger in relation to our contractual partners and as part of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in communicating quickly and efficiently and meeting the needs of our communication partner in communication via Messenger. We would also like to point out that we will not transfer the contact details provided to us to messengers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent at any time and object to communication with us via Messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is expected and the deletion does not conflict with legal storage obligations.

Reservation of referrals to other means of communication: Finally, we would like to point out that for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case when, for example, internal contracts require special secrecy or an answer via messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
  • Affected persons: communication partner.
  • Purposes of processing: Contact requests and communication; direct marketing (e.g. by email or post).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).


Further information on processing processes, procedures and services:
Slack: instant messaging service; service provider: Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105, USA; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://slack.com/intl/de-de/; Privacy statement: https://slack.com/intl/de-de/legal; Order processing contract: https://slack.com/intl/de-de/terms-of-service/data-processing; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://slack.com/intl/de-de/terms-of-service/data-processing; More information: Safety measures: https://slack.com/intl/de-de/security-practices.

Video conferences, online meetings, webinars, and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (collectively referred to as “conference”). When selecting conference platforms and their services, we comply with legal requirements.

Data processed through conference platforms: As part of participating in a conference, the conference platforms process the personal data of the participants mentioned below. The extent of processing depends, on the one hand, on which data is required as part of a specific conference (e.g. provision of login details or real names) and which optional information is provided by the participants. In addition to processing to carry out the conference, the participants' data can also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, professional position/function information, the IP address of Internet access, information about the participants' terminal devices, their operating system, the browser and its technical and language settings, information on the content communication processes, i.e. inputs in chats and audio and video data, as well as the use of others available standing functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users on the conference platforms, then further data can be processed in accordance with the agreement with the respective conference provider.

Logging and recording: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this is transparently notified to the participants in advance and they are asked — if necessary — for consent.

Participants' data protection measures: Please note the details of the processing of your data by the conference platforms in their privacy policies and, as part of the settings for the conference platforms, choose the optimal security and data protection settings for you. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by notifying roommates, locking doors and using, as far as technically possible, the function to obscure the background). Links to the conference rooms and access data must not be passed on to unauthorized third parties.

Information on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to recording conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in lists of participants, in the case of processing of conversation results, etc.). In addition, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; contact requests and communication; office and organizational procedures.
  • Legal bases: Consent (Article 6 (1) (1) (a) GDPR); contract performance and pre-contractual inquiries (Article 6 (1) (b) GDPR); legitimate interests (Article 6 (1) (f) GDPR).

Further information on processing processes, procedures and services:

application process

The application process requires that applicants provide us with the data necessary for their assessment and selection. What information is required is derived from the job description or, in the case of online forms, from the information provided there. In principle, the required information includes personal information, such as the name, address, a contact option and evidence of the qualifications required for a position. On request, we are also happy to inform you which information is required.

If provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted during transport, but not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the application between the sender and receipt on our server.

For purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements. Applicants are welcome to contact us about how to submit their application or send us the application by post.

Processing of special categories of data: If, as part of the application process, special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as status of severely disabled persons or ethnic origin) are requested from applicants so that the person responsible or the data subject can exercise the rights conferred on him or her under employment law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Article 9 (2) lit. b. GDPR, in case of protection vital interests of applicants or other persons in accordance with Art. 9 para. 2 lit. c. GDPR or for health care or occupational medicine purposes, for the assessment of the employee's ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. GDPR. If the special categories of data are provided on the basis of voluntary consent, they will be processed on the basis of Article 9 (2) lit. a. GDPR.

Deletion of data: In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to justified withdrawal by applicants, the deletion will take place no later than after the expiry of a period of six months so that we can answer any follow-up questions about the application and comply with our obligations to provide evidence under the rules on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax requirements.

Types of data processed: Inventory data (e.g. names, addresses); contact details (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents relating to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information provided voluntarily by applicants about their person or qualification).

Affected persons: Applicant.

Purposes of processing: Application process (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).

Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing processes, procedures and services:

  • Application via email: On our website, we offer applicants the opportunity to contact us by e-mail (jobs@hurra.com) on vacancies in our agency (https://www.hurra.com/about/agency-jobs/) to advertise on hurra.com. The documents sent electronically and personal data provided by you are processed in accordance with the applicable data protection regulations. For jobs in our affiliated companies, your submitted data may be passed on if this is necessary for the position.‍
  • Join.com: services related to employee recruitment/recruitment (search for employees, communication, application process, contract negotiations, pool of applicants); Service provider: JOIN Solutions GmbH, Schoenhauser Allee 36, 10435 Berlin, Germany; Legal bases: consent (Article 6 (1) (1) (a) GDPR), contract performance and pre-contractual inquiries (Article 6 (1) (b) GDPR), legitimate interests (Article 6 (1) (f) GDPR); Site: https://join.com; Privacy statement: https://join.com/de/datenschutz.‍
  • LinkedIn Recruiter: job application and application-related services within the LinkedIn platform; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.linkedin.com; TERMS AND CONDITIONS: https://legal.linkedin.com/dpa; Privacy statement: https://www.linkedin.com/legal/privacy-policy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses; Order processing contract: https://legal.linkedin.com/dpa.‍
  • Monster: services related to employee recruitment/recruitment (search for employees, communication, application process, contract negotiations); Service provider: Monster Worldwide Germany GmbH, Ludwig-Erhard-Strasse 14, 65760 Eschborn, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.monster.de; Privacy statement: https://www.monster.de/datenschutz/datenschutz/home.aspx.‍
  • Stepstone: services related to employee recruitment/recruitment (search for employees, communication, application process, contract negotiations); Service provider: StepStone Deutschland GmbH, Völklinger Strasse 1, 40219 Düsseldorf, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.stepstone.de; Privacy statement: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/.‍
  • Xing: job application and application-related services within the Xing platform; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.xing.com; Privacy statement: https://privacy.xing.com/de/datenschutzerklaerung.‍
  • Inclusion in a pool of applicants: Admission to a pool of applicants, if offered, is based on consent. Applicants are informed that their consent to join the talent pool is voluntary, has no influence on the ongoing application process and that they can withdraw their consent at any time in the future. If we are allowed to include your application in our pool of applicants for future vacancies, please note it in your cover letter or application documents. We then process your data on the legal basis of consent in accordance with Art. 6 para. 1 lit. a GDPR.

Cloud services

We use software services accessible via the Internet and run on their providers' servers (so-called “cloud services”, also known as “software as a service”) for the following purposes: document storage and administration, calendar management, email delivery, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms, or other content and information, and chats and participation in audio and video conferences. Within this framework, personal data may be processed and stored on the providers' servers, insofar as this is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on processes, contracts, other processes and their content. Cloud service providers also process usage data and metadata, which are used by them for security purposes and service optimization.

If we use cloud services to provide forms or documents and content to other users or publicly accessible websites, the providers can store cookies on users' devices for web analysis purposes or to remember user settings (e.g. in the case of media control).

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); image and/or video recordings (e.g. photographs or video recordings of a person).
  • Affected persons: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners; users (e.g. website visitors, users of online services); business and contractual partners.
  • Purposes of processing: Office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.); provision of contractual services and customer service.
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

  • Adobe Creative Cloud: applications and cloud storage for photo editing, video editing, graphic design, and web development; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Site: https://www.adobe.com/de/creativecloud.html; Privacy statement: https://www.adobe.com/de/privacy.html; Order processing contract: Is provided by the service provider; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses.
  • Amazon Web Services (AWS): services in the area of providing information technology infrastructure and related services (e.g. storage and/or computing capacity); Service provider: Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://aws.amazon.com/de/; Privacy statement: https://aws.amazon.com/de/privacy/; Order processing contract: https://aws.amazon.com/de/compliance/gdpr-center/; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses.

Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletters”) with the consent of the recipients or legal permission. If the content of the newsletter is specifically described as part of a subscription to the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us. In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name in order to address you personally in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double opt-in process: Registration for our newsletter generally takes place in a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign email addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes saving the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently comply with objections, we reserve the right to store the email address in a blocked list (so-called “block list”) for this purpose alone. The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been completed correctly. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.

Content: Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: Direct marketing (e.g. via email or post); reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); profiles with user-related information (creation of user profiles).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
  • Objection option (opt-out): You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will either find a link to cancel the newsletter at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.

Further information on processing processes, procedures and services:

  • Measurement of open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is first collected. This information is used to technically improve our newsletter based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening rates and click rates as well as storage of measurement results in user profiles and their further processing are based on user consent. Unfortunately, it is not possible to cancel the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 lit. a) GDPR).
  • Google Analytics 4: measuring the success of email campaigns and creating user profiles with a storage period of up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; legal basis: consent (Article 6 (1) (a) GDPR); Site: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy statement: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://business.safety.google/adsprocessorterms; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated; More information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).

Promotional communication via e-mail, post, fax or telephone

We process personal data for the purposes of promotional communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to promotional communication at any time. After revocation or objection, we will store the data required to prove previous authorization to contact or send you information for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of possible defense against claims. On the basis of the legitimate interest in permanently observing the user's revocation or objection, we also store the data required to avoid being contacted again (e.g. email address, telephone number, name, depending on the communication channel).

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
  • Affected persons: communication partner.
  • Purposes of processing: Direct marketing (e.g. via email or post).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).


Web analysis, monitoring and optimization

Web analysis (also known as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently or invite them to be reused. We can also understand which areas need optimization.

In addition to web analysis, we can also use test methods, for example to test and optimize different versions of our online offering or its components. Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes in particular websites visited and elements used there, as well as technical information, such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data with us or with the providers of the services we use, location data may also be processed.

The IP addresses of users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavioral profiling, use of cookies); provision of our online offering and usability; conversion measurement (measurement of the effectiveness of marketing measures); click tracking; A/B testing; heat maps (mouse movements by users, which are summarized to form an overall picture).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 (1) (a) GDPR).


Further information on processing processes, procedures and services:

  • Google Analytics 4: We use Google Analytics to conduct user analysis based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed during one or more usage processes, which search terms they have used, have accessed them again or have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies can be used. Analytics provides higher-level geographic location data by collecting the following metadata using IP search: “city” (and the derived latitude and longitude of the city), “continent,” “country,” “region,” “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The user's IP address is not logged and is abbreviated by the last two digits as standard. The abbreviation of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy statement: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://business.safety.google/adsprocessorterms; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated; More information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
  • Google Analytics in consent mode: In consent mode, personal user data is processed by Google for measurement and advertising purposes, subject to user consent. Consent is obtained from users as part of our online services. If the user's consent is missing in full, the data is only processed at an aggregated (i.e. not assigned and summarized to individual users) level. If consent only includes statistical measurement, no personal user data is processed for ad placement or measurement of advertising success (so-called “conversion”); Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://support.google.com/analytics/answer/9976101?hl=de.
  • OwaPro Tag Manager with External Consent: Administration and control of web analysis and tracking services on the website by rule-based triggering of code fragments (“tags”). Signals from consent management systems are also processed to enable tags to be executed in the tag management system in accordance with the settings made by a user; Service provider: Hurra Communications GmbH, Lautenschlagerstraße 23a, 70173 Stuttgart, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Privacy statement: https://www.hurra.com/datenschutz/.
  • OwaPro Essential Measurement: Measuring the performance of advertisements and measuring the reach of the website. The measurement is carried out by click tracking when a user is redirected after interaction with an advertisement and thus the advertiser's website request. The website links to a possible transaction (“conversion”) within the current visitor session (“session”) and the measurement of transactions as a basis for performance and success measurement; Service provider: Hurra Communications GmbH, Lautenschlagerstraße 23a, 70173 Stuttgart, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Privacy statement: https://www.hurra.com/datenschutz/; Objection option (opt-out): https://ssl.hurra.com/opt-out?cid=3723&ln=de .
  • Ads Defender Click Fraud: The “Ads Defender” service is used to analyze and prevent click fraud on our advertisements. Click fraud occurs when clicks on advertisements are generated by automatic tools or multiple clicks on advertisements are presumably not due to genuine user interest; Service provider: Hurra Communications GmbH, Lautenschlagerstraße 23a, 70173 Stuttgart, Germany; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.adsdefender.com/; Privacy statement: https://www.adsdefender.com/privacy-policy.
  • Microsoft Clarity: Software for analyzing and optimizing online offers based on feedback functions and pseudonymous measurements and analyses of user behavior, which may include, in particular, A/B tests (measurement of the popularity and usability of various content and functions), measurement of click routes and interaction with content and functions of the online offer; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://clarity.microsoft.com/; Privacy statement: https://privacy.microsoft.com/de-de/privacystatement;Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses.

Online marketing

We process personal data for online marketing purposes, which may include marketing advertising space or presenting advertising and other content (collectively referred to as “content”) based on users' potential interests and measuring their effectiveness. For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used to store the user information relevant to the presentation of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of users are also stored. However, we use available IP masking methods (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of the online marketing process, no clear user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we as well as the providers of online marketing processes do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or using similar procedures. These cookies can generally also be read out and analysed for the purpose of presenting content on other websites that use the same online marketing process, as well as supplemented with further data and stored on the server of the online marketing process provider.

As an exception, plain data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing process we use and the network connects the users' profiles with the above information. Please note that users can make additional agreements with providers, e.g. through consent as part of registration.

In principle, we only have access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures. Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

  • Types of data processed: usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); contact information (Facebook) (“contact information” is data that (clearly) identifies data subjects, such as names, email addresses and telephone numbers, which can be transmitted to Facebook, e.g. via Facebook pixel or upload for reconciliation purposes to create custom audiences; contact information is deleted after reconciliation to form target groups).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioral profiling, use of cookies); profiles with user-related information (creation of user profiles); provision of our online offering and usability; marketing; conversion measurement (measurement of the effectiveness of marketing measures); remarketing; target group formation (determination of target groups relevant for marketing purposes or other output of content).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR); legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
  • Objection option (opt-out): We refer to the data protection policies of the respective providers and the objection options provided to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, it is possible, on the one hand, to switch off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are offered in summary for respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices d) Across territories: https://optout.aboutads.info.


Further information on processing processes, procedures and services:

  • Facebook pixels and target group building (custom audiences): With the help of the Facebook pixel (or comparable functions, for transmitting event data or contact information via interfaces in apps), Facebook is on the one hand able to identify visitors to our online offer as a target group for displaying ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to send Facebook ads placed by us only to users on Facebook and within the services of partners cooperating with Facebook (so-called”Audience Network“) that have also shown an interest in our online offering or that have certain characteristics (e.g. interest in specific topics or products, which can be seen on the basis of the websites visited), which we transmit to Facebook (so-called “custom audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads meet the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://www.facebook.com; Privacy statement: https://www.facebook.com/about/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: the “Facebook-EU Data Transfer Amendment” applies (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of order processing by Facebook as a basis for processing event data from EU citizens in the USA and inclusion in the “Facebook Platform Terms of Use” (https://developers.facebook.com/terms) with regard to the independent processing of event data from Facebook as part of advertising; More information: The “data processing conditions” apply (https://www.facebook.com/legal/terms/dataprocessing/update) with regard to event data that Facebook processes on behalf of companies in order to provide companies with reports and analyses; in addition, the “Amendment for Responsible Persons” applies as an agreement on joint responsibility (Art. 26 (1) (3) GDPR), which is decisive in the case of independent processing of event data by Facebook for the purposes of targeting and improving and securing Facebook products.
  • Expanded matching for the Facebook pixel: In addition to the processing of event data as part of the use of the Facebook pixel (or comparable functions, e.g. in apps), contact information (data identifying individual persons, such as names, email addresses and telephone numbers) is also collected by Facebook within our online offering or transmitted to Facebook. The processing of contact information is used to create target groups (so-called “custom audiences”) for displaying content and advertising information based on the presumed interests of users. The collection, transmission and comparison with data available on Facebook is not carried out in plain text, but as so-called “hash values”, i.e. mathematical images of the data (this method is used, for example, when saving passwords). After reconciliation to create target groups, the contact information is deleted. Contact information is processed on the basis of an order processing agreement with Meta Platforms Ireland Limited (“data processing conditions”, https://www.facebook.com/legal/terms/dataprocessing), the “data security conditions” (https://www.facebook.com/legal/terms/data_security_terms); Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://www.facebook.com/legal/EU_data_transfer_addendum. Further information on the processing of contact information can be found in the “Terms of Use for Facebook Business Tools,” https://www.facebook.com/legal/technology_terms; Legal bases: Consent (Art. 6 (1) (a) GDPR).
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g. in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. For example, if a user is shown ads for products that they have shown interest in on other online offerings, this is referred to as “remarketing”; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://marketingplatform.google.com; Privacy statement: https://policies.google.com/privacy; More information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: Data processing conditions for Google advertising products: Information about the services Data processing conditions between persons responsible for third-country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as an order processor, data processing conditions for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: We use the “Google Ads” online marketing process to place ads on the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). We also measure the conversion of ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag.” However, we ourselves do not receive any information that can be used to identify users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://marketingplatform.google.com; Privacy statement: https://policies.google.com/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses:https://business.safety.google/adscontrollerterms; More information: Types of processing and processed data: https://privacy.google.com/businesses/adsservices; Data processing conditions between controllers and standard contractual clauses for third-country transfers of data:
  • Advanced conversions for Google Ads: When customers click on our Google ads and then use the advertised service (so-called “conversion”), the data entered by the user, such as the email address, name, home address or telephone number, can be transmitted to Google. The hash values are then compared with users' existing Google accounts in order to be able to better evaluate and improve users' interaction with the ads (e.g. clicks or views) and thus their performance; Legal bases: consent (Article 6 (1) (1) (a) GDPR); webpage: https://support.google.com/google-ads/answer/9888656; Privacy statement: https://business.safety.google/adsprocessorterms/; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://business.safety.google/adsprocessorterms/sccs/c2p/.
  • OwaPro Performance Measurement: Measuring the performance of advertisements and user behavior on the website to optimize marketing measures and analyze user and buyer behavior across all marketing channels. The measurement is carried out by click tracking when a user is redirected after interaction with an advertisement and thus the advertiser's website request. The website collects and links user interaction with the website, including transactions (“conversions”) over possibly multiple visitor sessions (“session”), to measure and optimize the performance of advertising campaigns across marketing channels and measures; Service provider: Hurra Communications GmbH, Lautenschlagerstraße 23a, 70173 Stuttgart, Germany; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Privacy statement: https://www.hurra.com/datenschutz/; Objection option (opt-out): https://ssl.hurra.com/opt-out?cid=3723&ln=de.
  • LinkedIn ads: Placement of advertisements within the LinkedIn platform and evaluation of ad results; service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: consent (Article 6 (1) (1) (a) GDPR); Site: https://business.linkedin.com/de-de/marketing-solutions/ads; Privacy statement: https://www.linkedin.com/legal/privacy-policy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://de.linkedin.com/legal/l/dpa; Objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; More information: https://legal.linkedin.com/dpa.

Presences on social networks (social media)

We maintain online presences within social networks and, within this framework, process user data in order to communicate with users active there or to offer information about us. We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably match the interests of users. For these purposes, cookies are usually stored on users' computers, in which user behavior and interests are stored. In addition, data can also be stored in the user profiles regardless of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks. Even in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to user data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).


Further information on processing processes, procedures and services:

  • Instagram: social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.instagram.com; Privacy statement: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the social network Facebook - Together with Meta Platforms Ireland Limited, we are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content that users view or interact with, or the actions they take (see “Things done and provided by you and others” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As stated in the Facebook data policy under “How do we use this information? “Facebook also explains, collects and uses information to provide analytics services, so-called “page insights,” for site operators so that they obtain insights into how people interact with their pages and with the content associated with them. We have signed a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must comply with and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Users' rights (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about page insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.facebook.com; Privacy statement: https://www.facebook.com/about/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://www.facebook.com/legal/EU_data_transfer_addendum; More information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data.

Plug-ins and embedded features and content

We integrate functional and content elements into our online offering, which are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”). Integration always requires that the third-party providers of this content process the users' IP addresses, as they would not be able to send the content to their browsers without the IP address. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third parties can also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and the operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and usability; provision of contractual services and customer service.
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing processes, procedures and services:

  • Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers from other providers (e.g. functional libraries that we use to display or make our online offer user-friendly). In doing so, the respective providers collect the IP address of users and can process it for purposes of transmitting the software to the user's browser and for security purposes as well as for evaluating and optimizing their offerings. - We include software in our online offering that we retrieve from servers from other providers (e.g. functional libraries that we use to present or make our online offering user-friendly). In doing so, the respective providers collect the IP address of the users and can process it for the purpose of transmitting the software to the user's browser and for security purposes as well as to evaluate and optimize their offer; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
  • Google Fonts (retrieved from Google server): Purchase of fonts (and symbols) for the purpose of technically safe, maintenance-free and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform presentation and taking into account possible licensing restrictions. The provider of the fonts is provided with the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary to provide the fonts depending on the devices used and the technical environment; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://fonts.google.com/; Privacy statement: https://policies.google.com/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses.
  • reCAPTCHA: We include the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by people and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with reCAPTCHA on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Data processing is based on our legitimate interest in protecting our online offering from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.google.com/recaptcha/; Privacy statement: https://policies.google.com/privacy; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for displaying advertisements: https://adssettings.google.com/authenticated.

Management, organization and auxiliary tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we comply with legal requirements.
Within this framework, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data on processes, contracts, other processes and their content.

If users are referred to the third-party providers or their software or platforms as part of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to comply with the privacy policies of the respective third-party providers.

  • Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); contract data (e.g. subject of contract, duration, customer category); contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Communication partners; users (e.g. website visitors, users of online services); business and contract partners.
  • Purposes of processing: Provision of contractual services and customer service; office and organizational procedures; reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing processes, procedures and services:

  • HubSpot: social media publishing, reporting (e.g. traffic sources, access figures, web analysis), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, United States; Legal bases: legitimate interests (Art. 6 (1) (f) GDPR); Site: https://www.hubspot.de; Privacy statement: https://legal.hubspot.com/de/privacy-policy; Order processing contract: https://legal.hubspot.com/dpa; Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses: https://legal.hubspot.com/dpa.


Amendment and update of the privacy policy

We ask you to regularly check the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.


Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is associated with such direct marketing.
  • Right of withdrawal in case of consent: You have the right to withdraw your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the relevant data is being processed and for information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
  • Right to delete and restrict processing: In accordance with legal requirements, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
  • Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you is contrary to the GDPR.


Supervisory authority responsible for us:
The State Commissioner for Data Protection and Freedom of Information Baden-Württemberg
Lautenschlagerstrasse 20
70173 Stuttgart
https://www.baden-wuerttemberg.datenschutz.de/kontakt-aufnehmen/

Status: 29.02.2024