Privacy Policy

Preamble

With the following privacy policy we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) we process, for which purposes and to what extent, in connection with the provision of our application.

The terms used are not gender-specific.

Controller

Hevrora
c/o Smarvo 234
Südstraße 31,
47475 Kamp-Lintfort

Legal notice (Impressum): /legal-notice

Overview of processing

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

Types of data processed

• Inventory data.
• Employee data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and procedural data.
• Log data.
• Health-adjacent and special categories of personal data (Art. 9 GDPR), where voluntarily provided in the application (e.g. anthropometrics, blood markers, health flags).

Categories of data subjects

• Customers and clients.
• Employees.
• Prospective customers.
• Communication partners.
• Users.
• Business and contractual partners.
• Third parties.
• Whistleblowers.

Purposes of processing

• Provision of contractual services and fulfilment of contractual obligations.
• Communication.
• Security measures.
• Reach measurement.
• Office and organisational procedures.
• Organisational and administrative procedures.
• Feedback.
• Profiles with user-related information.
• Authentication procedures.
• Provision of our online offering and user experience.
• Information technology infrastructure.
• Whistleblower protection.
• Business processes and commercial procedures.

Relevant legal bases

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

• Consent (Art. 6(1) sentence 1 lit. a GDPR) — The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR) — Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6(1) sentence 1 lit. c GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
• Special categories (Art. 9 GDPR) — This application does not collect a separate explicit Art. 9(2)(a) consent. We do not claim that such consent exists. Please do not enter special-category health data (diagnoses, medical records, genetic data). Voluntary plan inputs (anthropometrics, optional lab numbers you type) are processed as user-supplied content to generate the requested plan under Art. 6(1) sentence 1 lit. b GDPR. See the dedicated Art. 9 section below.

National data protection rules in Germany: In addition to the GDPR, national data protection rules apply in Germany. This includes in particular the Federal Data Protection Act (BDSG). The BDSG contains special rules on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer as well as automated individual decision-making including profiling. State data protection laws of the individual federal states may also apply.

Security measures

We take appropriate technical and organisational 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 varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

Measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, ensuring availability and segregation relating to the data. We have also established procedures that ensure the exercise of data subject rights, erasure of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections with TLS/SSL encryption (HTTPS): To protect user data transmitted via our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) encrypt information transmitted between the website or app and the user’s browser (or between two servers). When a website is secured with an SSL/TLS certificate, this is indicated by HTTPS in the URL.

Transfer of personal data

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

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this always takes place in accordance with legal requirements.

For data transfers to the USA we primarily rely on the Data Privacy Framework (DPF), recognised as a secure legal framework by an adequacy decision of the EU Commission dated 10 July 2023. In addition, we have concluded Standard Contractual Clauses with the respective providers that meet the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard provides comprehensive protection: the DPF forms the primary layer of protection, while the Standard Contractual Clauses serve as additional security. Should changes occur within the DPF framework, the Standard Contractual Clauses act as a reliable fallback.

For individual service providers we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies are available on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/.

For data transfers to other third countries, corresponding safeguards apply, in particular Standard Contractual Clauses, explicit consent or transfers required by law. Information on third-country transfers and applicable adequacy decisions is available from the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General information on data storage and erasure

We erase personal data that we process in accordance with legal requirements as soon as the underlying consents are withdrawn or there are no further legal bases for processing. This applies where the original purpose of processing ceases to apply or the data is no longer required. Exceptions apply where legal obligations or special interests require longer retention or archiving of the data.

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

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

Where several retention periods or erasure deadlines are stated for a piece of data, the longest period always applies. Data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons is processed only for the reasons that justify its retention.

Retention and erasure of data: The following general periods apply to retention and archiving under German law:

• 10 years — Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents required to understand them (§ 147(1) no. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) no. 1 in conjunction with (4) HGB).
• 8 years — Accounting records such as invoices and cost receipts (§ 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO and § 257(1) no. 4 in conjunction with (4) HGB).
• 6 years — Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation (§ 147(1) nos. 2, 3, 5 in conjunction with (3) AO, § 257(1) nos. 2 and 3 in conjunction with (4) HGB).
• 3 years — Data required to consider potential warranty and damages claims or similar contractual claims and rights and to process related enquiries, based on prior business experience and common industry practice, for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Start of the period at the end of the year: If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the triggering event is the effective date of termination or other end of the legal relationship.

Rights of data subjects

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

• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6(1) lit. e or f GDPR, including profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw consents at any time.
• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
• Right to rectification: You have the right, in accordance with legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to demand restriction of the processing of the data.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships and related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer enquiries.

We process this data to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other performance disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and company organisation. We also process the data on the basis of our legitimate interests in proper and economic business management and security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).

Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, usage intensity and frequency).

Data subjects: Customers and clients; prospective customers; business and contractual partners.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; business processes and commercial procedures.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); legal obligation (Art. 6(1) sentence 1 lit. c GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Payment procedures

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options. The only payment service provider integrated in this application is Stripe (checkout sessions, subscriptions, customer portal). No other payment service providers are integrated as first-party payment methods in the application code.

The data processed by Stripe includes inventory data such as name and address, payment method data (e.g. card details processed by Stripe), as well as contract, sum and recipient-related information. Payment card details are processed by Stripe; we receive confirmation or status information and subscription metadata, not full card numbers. Please refer to Stripe’s terms and privacy information.

Payment transactions are subject to Stripe’s terms and privacy notices. We also refer to these for further information and assertion of withdrawal, access and other data subject rights.

Types of data processed: Inventory data; payment data; contract data; usage data; meta, communication and procedural data.

Data subjects: Customers and clients; prospective customers; users.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; business processes and commercial procedures.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Stripe: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA (and affiliated entities, including Stripe Payments Europe, Ltd.). Website: https://stripe.com. Privacy policy: https://stripe.com/privacy. Third-country transfers: Data Privacy Framework (DPF), supplemented by Standard Contractual Clauses where applicable.

Provision of the online offering and web hosting

We process users’ data in order to be able to provide them with our online services. For this purpose we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

Types of data processed: Usage data (e.g. page views and length of stay, click paths); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved); log data (e.g. log files concerning logins or the retrieval of data or access times).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: Provision of our online offering and user experience; information technology infrastructure (operation and provision of information systems and technical devices); security measures.

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

Further information on processing operations, procedures and services:

• Collection of access data and log files:Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the retrieved web pages and files, date and time of retrieval, data volumes 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. Server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability. Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is required for evidence purposes is exempt from erasure until the respective incident has been finally clarified.
• Hosting and content delivery: We use hosting and infrastructure services from specialised providers to operate this application securely and efficiently. These providers process usage and meta data on our behalf under appropriate data processing agreements.

Application data hosting (Firebase / Google Cloud)

To provide authentication, database storage and server-side functions we use Google Firebase / Google Cloud services. This includes in particular Firebase Authentication (user accounts, session cookies), Cloud Firestore (user profiles, plans, progress, subscription metadata) and Firebase Admin on our servers.

Types of data processed: Inventory and contact data (e.g. email, display name); authentication and session data; application content and usage data (plans, profiles, progress entries); payment and subscription metadata (without full card data — payments via Stripe); meta and log data.

Data subjects: Users.

Purposes: Performance of the contract; authentication; storage and synchronisation of application data; security measures.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Google LLC, USA (Firebase / Google Cloud).

Legal bases:Performance of a contract (Art. 6(1) sentence 1 lit. b GDPR); legitimate interests in secure operation (Art. 6(1) sentence 1 lit. f GDPR). We do not collect Art. 9(2)(a) consent for health-adjacent inputs (see section “Health-adjacent and special category data”).

Privacy information: https://firebase.google.com/support/privacy; https://cloud.google.com/terms/cloud-privacy-notice.

Third-country transfers: Data Privacy Framework (DPF), supplemented by Standard Contractual Clauses where applicable.

Health-adjacent and special category data (Art. 9 GDPR)

Seltara is a health, nutrition and performance application. Users may voluntarily enter data that constitute health data or health-adjacent information, or that may relate to special categories of personal data within the meaning of Art. 9(1) GDPR. This includes in particular:

• Anthropometrics and body measurements (e.g. weight, height, age-related profile data);
• Lab and blood markers and related interpretations (blood engine);
• Health flags and context (e.g. pregnancy, lactation, kidney-related flags, medication notes in the supplement advisor);
• Nutrition, training and supplement inputs insofar as they may allow inferences about health.

Purposes: Generating and displaying personalised plans and evaluations in the application (nutrition, supplements, workouts, blood-marker guidance); storage in the user account for continued use. This is not a medical diagnosis and does not replace professional medical advice.

Legal bases: We do not operate an Art. 9(2)(a) explicit-consent collection in the product. Processing of the voluntary inputs you type to generate a requested plan is based on performance of the contract (Art. 6(1) sentence 1 lit. b GDPR). We ask you not to submit special-category data under Art. 9(1). If you nevertheless type such data, delete it or your account; we do not treat an uncollected consent checkbox as a legal basis.

Recipients: Processing in our infrastructure and by processors (in particular Firebase/Firestore, see above). Stripe payment processing does not process blood-marker content as payment data.

Retention:For as long as the user account exists and the data are required for the stated purposes; on account deletion in accordance with the application’s deletion processes and legal retention duties. You may correct data in the application and request account deletion.

Deletion: You can remove health-adjacent inputs in the application or delete your account. Contact [email protected] for questions. Because we do not collect Art. 9(2)(a) consent, there is no separate consent-withdrawal control.

Use of cookies

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

Notes on consent:We use cookies and similar technologies in accordance with legal regulations. Analytics/marketing technologies are loaded only after explicit per-category opt-in. Our consent choice is stored in the browser’s localStorage under the key seltara.cookie-consent as versioned JSON (v, analytics, marketing) — not as a separate opt-in cookie. That localStorage record is what gates optional tags. When you save a choice, we may also write a privacy-preserving, non-PII consent receipt to our application server logs as evidence of consent under Art. 7(1) GDPR (no account, email, or user id linkage; if the server log request fails, your browser choice still applies). You can change your choice via “Cookie Settings” in the footer (Accept all / Reject non-essential / Manage preferences). Strictly necessary storage (e.g. session cookie __session, theme preferences) is set without marketing or analytics consent. Details: Cookie Policy.

Notes on legal bases under data protection law: Consent (Art. 6(1) sentence 1 lit. a GDPR) for analytics/marketing; legitimate interests or contract necessity (Art. 6(1) sentence 1 lit. f or b GDPR) for strictly necessary storage.

Storage duration: With regard to the storage duration, the following types are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g. browser or mobile application). Our authentication session cookie __session is httpOnly and limited by server max-age configuration.
• Permanent cookies / localStorage: Preference and consent entries may remain until you clear them. Unless we provide users with explicit information about the type and storage duration, users should assume that non-session storage can last up to two years or until cleared.

General information on withdrawal and objection (opt-out): Users can withdraw their consents at any time via Cookie Settings and also declare an objection to processing in accordance with legal requirements. Users can also restrict cookies in their browser settings (though this may limit functionality).

Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); consent (Art. 6(1) sentence 1 lit. a GDPR).

Registration, login and user account

Users can create a user account. As part of registration, users are informed of the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular login information (username, password and an email address).

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by email about processes relevant to their user account, such as technical changes.

Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. textual or pictorial messages and contributions as well as information relating to them); usage data; meta, communication and procedural data; log data.

Data subjects: Users.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organisational and administrative procedures; provision of our online offering and user experience.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Further information:

• Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users.
• No obligation to retain data: It is the responsibility of the users to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

Single sign-on

“Single sign-on” or “SSO” authentication services allow users to sign in to our online offering using a user account with a single sign-on provider (e.g. Google). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via button.

Authentication takes place directly with the respective single sign-on provider. In the course of such authentication, we receive a user ID with the information that the user is logged in under this user ID at the respective single sign-on provider and an ID that cannot be used by us for other purposes (so-called “user handle”). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected during authentication and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, it can be different data, usually the email address and the username. The password entered with the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are asked to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually occurs. If, for example, users’ email addresses change, users must change these manually in their user account with us.

We can use single sign-on, if agreed with users, as part of or prior to the fulfilment of the contract, if users have been asked to do so within the framework of a consent and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure login system.

Types of data processed: Inventory data; contact data; usage data; meta, communication and procedural data.

Data subjects: Users.

Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; authentication procedures.

Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR); consent (Art. 6(1) sentence 1 lit. a GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Further information: The only single sign-on option offered in this application is Google sign-in via Firebase Authentication. No other SSO providers are integrated. Google Ireland Limited / Google LLC process data in accordance with their privacy policies and Firebase privacy information. Where data is transferred to the USA, appropriate safeguards (including the Data Privacy Framework and/or Standard Contractual Clauses where applicable) are observed. See also the Firebase section above.

Contact and enquiry management

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

Types of data processed: Inventory data; contact data; content data; usage data; meta, communication and procedural data.

Data subjects: Communication partners.

Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online offering and user experience.

Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); performance of a contract and pre-contractual enquiries (Art. 6(1) sentence 1 lit. b GDPR).

Web analysis, monitoring and optimisation

Web analysis (also referred to as “reach measurement”) is used to evaluate the visitor flows of our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis we can, for example, recognise at what time our online offering or its functions or content are most frequently used, or invite reuse. We can also understand which areas need optimisation.

In addition to web analysis, we can also use testing procedures, e.g. to test and optimise different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarised 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 to us or to the providers of the services we use, location data may also be processed.

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, within the framework of web analysis, A/B testing and optimisation, no clear data of users (such as email addresses or names) are 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.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data; meta, communication and procedural data.

Data subjects: Users.

Purposes of processing: Reach measurement; profiles with user-related information; provision of our online offering and user experience.

Security measures: IP masking (pseudonymisation of the IP address).

Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR); legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).

Google Tag Manager (GTM):We use Google Tag Manager as a container to deliver analytics tags after your consent. The GTM script is loaded only after consent (Consent Mode defaults to “denied”); in production only when a valid container ID is configured. Provider: Google Ireland Limited / Google LLC. Privacy: https://business.safety.google/privacy/. Legal basis: consent (Art. 6(1) sentence 1 lit. a GDPR).

Google Analytics: Where configured in the GTM container, Google Analytics measures use of our online offering on a pseudonymous basis (including IP masking where applied). It runs only after consent and via GTM. Provider: Google Ireland Limited / Google LLC. Further information and opt-out options are available from Google (e.g. Ad Settings).

Plugins and embedded content

We generally do not embed third-party media plugins (e.g. maps or social embeds) that load remote content on every page view. Fonts are self-hosted via Next.js next/font (Geist Sans / Geist Mono); we do not load fonts from third-party font CDNs or remote font APIs.

Where third-party scripts are used (GTM/Analytics after consent; Stripe checkout on redirect; Google/Firebase authentication), the IP address and related technical data may be processed by those providers as described in the corresponding sections.

Types of data processed: Usage data; meta, communication and procedural data (where third-party services are invoked).

Data subjects: Users.

Purposes of processing: Provision of our online offering and user experience; analytics after consent.

Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR) for optional tags; legitimate interests (Art. 6(1) sentence 1 lit. f GDPR) for self-hosted fonts and necessary delivery.

Privacy information for whistleblowers

If you submit reports via our whistleblower procedure, we process the data you provide solely for the purpose of receiving, reviewing and handling the report and for complying with legal obligations. Legal bases may include legal obligations and legitimate interests in protecting our organisation and the persons concerned (Art. 6(1) lit. c and f GDPR). Please provide only the information necessary for processing the report. For questions, contact [email protected].

Changes and updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

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

Definitions

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

• Inventory data: Inventory data includes information necessary for the identification of natural or legal persons and characteristics, attributes or similar that characterise them (e.g. names, addresses, contact information).
• Content data: Content data includes information generated in the course of creating, editing and publishing content of all kinds, as well as information communicated in the course of exchanges (e.g. text or image contributions, messages).
• Employees: Employees are persons in an employment relationship with us, including temporary staff, freelancers and other persons in a comparable relationship.
• Consent:Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
• Legitimate interests: Legitimate interests are interests of the controller or a third party that can justify processing personal data, provided they are not overridden by the interests or fundamental rights and freedoms of the data subject.
• Meta, communication and procedural data: Data such as IP addresses, timestamps, identification numbers, procedural information and persons involved in communication or technical processes.
• Personal data:“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of profile information includes any kind of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.).
• Log data: Log data is information about events or activities recorded in a system or network (e.g. timestamps, IP addresses, user actions, error messages).
• Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and may include behaviour or interests of visitors in certain information, such as website content.
• Controller:“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing:“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, whether collecting, evaluating, storing, transmitting or erasing.
• Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties, documenting the conditions under which services or products are provided, exchanged or sold.
• Payment data: Payment data includes all information required to process payment transactions between buyers and sellers (e.g. payment amounts, transaction data, billing information).
• Usage data: Usage data is data about how services or digital offerings are used (e.g. pages visited, time spent, click behaviour).