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Privacy policy

Last update:

Privacy Policy

As of June 16, 2025

Table of contents

Responsible person

Dr. Florestan Goedings, Rechtsanwalt

Mühlenstr. 8a
14167 Berlin

E-Mail-Adresse: goedings@projekt-jurist.com

Overview of processing

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

Types of data processed

  • Inventory data.
  • Contact data.
  • Content data.
  • Usage data.
  • Metadata, communication data, and process data.

Categories of data subjects

  • User.

Purposes of processing

  • Communication.
  • Security measures.
  • Audience measurement.
  • Organizational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Public relations.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases 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 their consent to the processing of personal data concerning them for a specific purpose or for several specific purposes.
  • Legitimate interests (Article 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require protection of personal data do not override those interests.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss DSG, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the Swiss DSG.

Security 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 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.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

Transmission of personal data

As part of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content 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.

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 as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the EU Commission’s requirements and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary layer of protection, while the standard contractual clauses serve as additional security. Should changes occur within the scope of the Data Protection Framework, the standard contractual clauses will act as a reliable fallback option. This ensures that your data remains adequately protected, even in the event of any political or legal changes.

For each service provider, we will 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 can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission’s information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or no further legal basis for the processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax law reasons, or whose retention is necessary for legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If multiple retention periods or deletion periods are specified for a given date, the longest period always applies.

If a period does not explicitly begin on a specific date and is at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within the framework of which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.

We process data that is no longer retained for its originally intended purpose, but due to legal requirements or other reasons, exclusively for the reasons that justify its retention.

Further information on processing procedures, methods and services:

  • Retention and deletion 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, as well as the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).
    • 8 years – Accounting documents, such as invoices and cost receipts (Section 147 (1) Nos. 4 and 4a in conjunction with (3) Sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
    • 6 years – Other business documents: received commercial or business letters, copies of sent commercial or business letters, and other documents relevant for tax purposes, e.g., timesheets, operating statements, calculation documents, price labels, and also payroll documents, provided they are not already accounting documents, and cash register slips (Section 147 (1) Nos. 2, 3, and 5 in conjunction with Section 3 of the German Fiscal Code (AO), Section 257 (1) Nos. 2 and 3 in conjunction with Section 4 of the German Commercial Code (HGB).
    • 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 195 and 199 of the German Civil Code).

Rights of data subjects

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

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; 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 purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of withdrawal of consent: You have the right to withdraw consent given at any time.
  • Right of information: You have the right to request confirmation as to whether the data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the statutory requirements.
  • Right to rectification: You have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you in accordance with the statutory requirements.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common, and machine-readable format, in accordance with the statutory provisions, or to request that it be transmitted to another controller.
  • 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 believe that the processing of personal data concerning you violates the provisions of the GDPR.

Use of cookies

The term “cookies” refers to functions that store and retrieve information from users’ end devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online services, as well as creating analyses of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain users’ consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and retrieving information is essential to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be revoked at any time. We provide clear information about the scope of this consent and which cookies are used.

Notes on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

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

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

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, including by using the privacy settings of their browser.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a consent management solution that obtains users’ consent to the use of cookies or to the procedures and providers named within the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar technologies used to store, read, and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are saved to avoid further queries and to be able to provide evidence of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using similar technologies in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Feedback (e.g., collecting feedback via online forms); provision of our online offering and user-friendliness; security measures; organizational and administrative procedures.
  • Storage and deletion: Deletion in accordance with the information in the “General information on data storage and deletion” section.
  • Legal basis: Legitimate interests (Article 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves may be held liable for the comment or contribution and are therefore interested in the identity of the author.
    Furthermore, we reserve the right to process user information for spam detection based on our legitimate interests.
    On the same legal basis, we reserve the right to store users’ IP addresses for the duration of surveys and to use cookies to prevent multiple voting.
    The personal information provided in comments and contributions, any contact and website information, as well as the content information, will be permanently stored by us until the user objects; Legal basis: legitimate interests (Art. 6 (1) (f) GDPR).

Web analysis, monitoring and optimization

Web analytics (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Using reach analysis, we can, for example, identify when our online offering or its functions or content are most frequently used, or encourage reuse. It also enables us to understand which areas require optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles—data summarized for a usage process—may be created for these purposes, and information may be stored in a browser or device and then read out. 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 consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.

In addition, users’ IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective processes.

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

  • Types of data processed: Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g., access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the “General information on data storage and deletion” section. Cookies are stored for up to two years. (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years.)
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering 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 analytics information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they used, accessed these again, or interacted with our online offering. The time and duration of use are also stored, as are the sources of users who refer to our online offering and the technical aspects of their devices and browsers.
    Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used for this purpose. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing;
    Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
    Legal basis: Consent (Art. 6 (1) (a) GDPR);
    Website: https://marketingplatform.google.com/intl/de/about/analytics/; 
    Security measures: IP masking (pseudonymization of the IP address);
    Privacy policy: https://policies.google.com/privacy; 
    Data processing agreement: https://business.safety.google/adsprocessorterms/; 
    Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses(https://business.safety.google/adsprocessorterms), Data Privacy Framework (DPF)Standard contractual clauses ( https://business.safety.google/adsprocessorterms); 
    Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements:https://myadcenter.google.com/personalizationoff. 
    Further information: https://business.safety.google/adsservices/ (Types of processing and data processed).

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, 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 could result in risks for users, for example, because it could make it more difficult to enforce user rights.

Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These profiles may, in turn, be used to place advertisements within and outside the networks that presumably correspond to the users’ interests. Therefore, cookies are generally stored on users’ computers in which the user behavior and interests are stored. In addition, user profiles can also store data independent of the devices used by users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can directly take appropriate measures and provide information. If you still need assistance, please contact us.

  • Types of data processed: Contact details (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or visual messages and posts, as well as related information, such as authorship or time of creation); Usage data (e.g., page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Communication; Feedback (e.g., collecting feedback via online form); Public relations.
  • Retention and deletion: Deletion in accordance with the information in the “General information on data storage and deletion” section.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • LinkedIn: Social network – We, together with LinkedIn Ireland Unlimited Company, are responsible for collecting (but not further processing) visitor data used to create the “Page Insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions they take. We also collect details about the devices used, such as IP addresses, operating systems, browser types, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
    We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which, in particular, regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of those affected (i.e., users can, for example, address requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint controllership is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA;
    Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland;
    Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR);
    Website: https://www.linkedin.com; 
    Datenschutzerklärung: https://www.linkedin.com/legal/privacy-policy; 
    Basis for third country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://legal.linkedin.com/dpa), Data Privacy Framework (DPF) Standard Contractual Clauses (https://legal.linkedin.com/dpa). 
    Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Xing: Social network;
    Service provider:New Work SE, Am Strandkai 1, 20457 Hamburg, Germany;
    Legal basis: Legitimate interests (Article 6 (1) (f) GDPR);
    Website: https://www.xing.com/. 
    Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt this privacy policy as soon as changes to the data processing we carry out 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 ask you to check the information before contacting us.

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