1. General information about data processing
In the following, we would like to inform you about the processing of your personal data by us, our data protection principles and your rights as a data subject.
The responsible authority is:
Telephone: +49 (0)9321 9064 1800
You can contact our data protection officer at:
Data Protection Officer
1.1. Data collection and origin of data
We collect the data that you provide to us when using our web pages.
Furthermore, we collect data in order to establish and develop a customer relationship with you as a customer or to enter into contracts with partners or provide services or for billing purposes. We collect data that you provide to us when registering for use of our services, in particular software, and when placing orders.
If you enter into a “contact relationship” with us (e.g. enquiries or offers for services via a contact form, newsletter registration, conclude supplier contracts with us or apply for a job with us, we will collect and process this data – insofar as this is necessary or appropriate according to Article 6 (f) GDPR.
We will also continue to collect data from publicly accessible sources (e.g. company register, your web pages, press articles, etc.) within the scope of permissibility according to Article 6 (f) GDPR.
Personal data that we collect and store in this way may include:
- IP address and usage data when retrieving website content
- Name and address and other contact details (telephone numbers, email address, fax number, etc.), registration numbers, names and addresses of authorised representatives, account information and the relevant data of relevant contact persons specified by you as a customer of our services plus other data you enter, e.g. data concerning your customers or employees, in particular with respect to use of our software (including during any free-of-charge trial periods)
- Name and contact details in the context of establishing and handling a contact relationship or a supplier relationship
- Name, email, password and requested web address when registering for use of our services
- Name and email address when subscribing to the newsletter and dispatch information about the respective newsletters
- Email address, name and other data entered when submitting ideas
- Email address for the purpose of holding a webinar
- Name and address and other contact details (telephone number, email address, etc.), names and addresses of authorised representatives, account information and the relevant data of relevant contact persons specified by you as a partner for use of our services plus other data you enter, e.g. data concerning your employees, in particular when ordering our partner training sessions
- Name when using the comment function in our blog
- Last name, first name and email address when including applicant in our talent pool
- Last name, first name and other data entered when using our chat-system
- IP address when using the Albacross service
- IP address and name when using the ProductBoard service
- IP address when logging in with your Google account in our software
- IP address and information about browser settings when using Microsoft Advertising
All personal data is only collected within the framework of legal permission or if you have granted us your consent to do so.
1.2. General information about using and sharing personal data
We use your personal data to enable you to use our website. Furthermore, data is processed and transmitted when you use our web pages for the purpose of anonymised analysis (e.g. Google Analytics) if you have given your consent.
In general, we use your personal data in order to establish and fulfil a contract with you as a customer or partner, and also for billing purposes. If you want to use our services, you first have to register via our website and enter your details.
If you enter into a contact, supplier or application relationship with us, we will use your data to establish and fulfil or handle this relationship and – where applicable – for billing purposes.
In addition, we use data lawfully obtained by us for the purpose of advertising by post and additionally by email or telephone, provided that you have specifically and legitimately consented to this.
Overall, it may also be necessary for us to disclose your data to external service providers as part of order processing. We will not sell your personal data to third parties or market it in some other way.
Data may be transferred to third countries within the context of the administration, development and operation of IT systems and only to the extent that a) the transfer is generally permitted and b) the particular requirements for a transfer to third countries are satisfied, in particular the data importer shall guarantee an appropriate level of data protection according to the EU standard contractual clauses for the transfer of personal data to processors established in third countries. The basis for this are the provisions of the GDPR and the German Federal Data Protection Act. Data may also be transferred when you use our web pages.
A processing of data takes place when using the service of Intercom to conduct product tours, to send messages and to provide information via the chat system.
In addition, processing and transfer of data occurs when using our websites when we place advertisements with Google Ads or Microsoft Advertising.
If you send us ideas via our website or messages via our system after registration, processing and transmission of your data will take place.
Submit ideas to us through our ProductBoard website, we process and transmit the data you enter there.
If you apply to us via our online application form, we process and transmit the data you enter there.
If you use the Albacross service, we will process and transmit your data.
2. Purposes of data processing
We process the above personal data in accordance with the provisions contained in the GDPR and the German Federal Data Protection Act (BDSG).
2.1 Processing for the fulfilment of contractual or pre-contractual obligations (Article 6 (1) (b) GDPR)
Personal data is processed in order to enable you to use our website, to fulfil a contract with you as a customer or partner, and also to establish a contact or application relationship. The purposes of data processing and its necessity are primarily based on the purposes specifically defined by the aforementioned legal relationships.
In the context of a contract with you as a customer or partner, this includes in particular the establishment, development and fulfilment of such a contract, including elements relating to consultation and billing, in addition to the services ordered by you.
Your registration as a customer allows us to process your orders and handle internal administrative matters.
Processing also takes place in order to handle your queries, initiate a customer relationship or a comparable contact relationship and also to process applications.
If you log into your Google account in our software, data is processed to enable you to use it.
It may also be necessary for us to disclose your data to group companies or external service providers as part of order processing for the aforementioned purposes.
2.2 Processing in the balancing of interests (Article 6 (1) (f) GDPR)
To the extent necessary for our purposes, we process your data beyond the actual fulfilment of the pre-contract or contract in order to safeguard our legitimate interests or those of third parties, provided that your interests do not outweigh the prevention of such processing:
- Anonymisation of IP addresses when using our website for statistical purposes, data security and website optimisation
- Use of technically necessary cookies (essential) to ensure optimal functionality of the website and guarantee a user-friendly and effective website
- Potential measures for the data security of our website such as, in particular, saving IP addresses, assuming that the specific threat situation makes this appropriate
- Establishment and fulfilment of contact relationships to the extent required
- Processing applications to the extent required
- Collection of outstanding debts; here we cooperate with reliable partners
- Holding our webinars to the extent required
- Using our software and website with Intercom to conduct product tours, send messages, and provide information through the chat system
- Use of our blog to submit a comment
- Use of our website with Personio to apply for a job through an online application form
- Use of our website with YouTube to market our products
- Use of LinkedIn for page insights to analyse the types of actions taken on our page
- Use of Facebook and Instagram for page insights when you visit our company pages on Facebook and Instagram to analyse the types of actions taken on our page
2.3 Processing in the context of your consent (Article 6 (1) (a) GDPR)
If you consent to the processing of personal data for a specific purpose (e.g. receipt of a newsletter, use of Google Analytics, Google Ads, Microsoft Advertising to record the user behavior inclusion of an applicant in our talent pool) in accordance with existing legislation, we will process this data based on this consent. You can revoke this consent at any time without affecting the lawfulness of any processing carried out with consent prior to its withdrawal.
2.4 Processing due to legal requirements (Article 6 (1) (c) GDPR)
We will process your personal data insofar as we are subject to a statutory obligation, for example:
- Statutory retention requirements or disclosure or supervisory obligations vis-à-vis public institutions within the legal framework
- For the purpose of obtaining consent to data processing activities (e.g. with the consent management tool Borlabs Cookie) and documentation matters
3. Data transmission to third parties
Within our company, your data can be accessed by people who are involved in its processing, to the extent necessary or appropriate. Service providers and vicarious agents used by us, for example, service providers in the area of IT services, telecommunications and logistics, can also receive access to the personal data for these purposes if they observe our written data protection instructions as well as general data secrecy as part of order processing and – to the extent applicable – the secrecy of telecommunications.
We cooperate with third parties for the purpose of collecting outstanding debts.
In particular, we do not share personal data with third parties for purposes of advertising or address trading.
When using our website, data will be transmitted to analysis services. If you send us your ideas, your data will be transmitted to ProductBoard. If you use our product tours, if we send you a message via Intercom or if we provide you with information via the chat system, some data will be transmitted to Intercom. If you use the Albacross service on our website, data will be transmitted to Albacross.
4. Data transmission to third countries or international organisations
Data transmission to countries outside the EU or EEA (“third countries) will only take place if this is deemed necessary for the purpose of executing the contractual relationship. With respect to other contractual relationships, for example, a contact relationship or an application, such data transmission will only take place for the purpose of fulfilling this contractual relationship or where this is deemed appropriate based on a legitimate interest in exceptional cases. The same applies to the use of our web pages from locations outside the EU or EEA.
When using our website, data is transmitted to analysis services. If you send us your ideas via the website with ProductBoard your data will be transmitted to ProductBoard.
5. Length of data storage
We store your IP address and usage data for the duration of your visit whenever you access our web pages. Furthermore, the IP address is stored to the extent appropriate for data security and information or preventing security or data protection breaches, whereby appropriateness is determined by the specific threat situation. In this case, the IP addresses are only stored for as long as is deemed appropriate for the aforementioned purposes, and generally speaking for a period not exceeding three months. In the event of a criminal charge or prosecution, or the enforcement of claims against individuals who have committed security or data protection breaches, the data can be stored and used until the matter is finally resolved or the claims are enforced.
We store the data for the purpose of establishing, developing and fulfilling a contract with you as a customer or partner. The data is deleted once it is no longer required. The data can be stored for the period in which claims against us can be asserted. If we are legally required to retain data, for example, because of tax or commercial obligations, we will store the data for the respective period (up to 10 years). If you as a payer raise an objection within the period prescribed, the data will be stored until the objections or collection of unpaid amounts have been resolved.
As part of a contact relationship, contact details and communications data are stored and used to the extent deemed necessary for the respective communication purpose or as deemed appropriate.
If you want to watch a webinar, your email address will be stored provided that this is required for the purposes of the webinar.
As part of an application relationship, contact details and application data are stored and used to the extent deemed necessary for the respective application purpose or as deemed appropriate. If the application is unsuccessful, the data will be deleted following communication of this decision, unless there are other legitimate interests on the part of the controller preventing this. Other legitimate interests in this context may include, for example, a burden of proof in proceedings in accordance with the General Act on Equal Treatment (AGG).
If you as an applicant grant us your consent to be included in the talent pool, your data will be stored until you revoke your consent or we delete your profile.
If you subscribe to our newsletter, we will store and use your data until you unsubscribe from the newsletter or we decide to cancel the newsletter. Your consent and the dispatch history will continue to be stored until any potential injunctive claims on your side become time-barred. However, we will no longer use the data to continue sending newsletters.
6. Collection of outstanding debts
Where, in the context of safeguarding our legitimate interests, the collection of outstanding debts is required from the contractual relationship or in some other way – and to the extent that these do not outweigh the interests or fundamental rights and freedoms of the data subject that require the protection of personal data – we will assign legal persons the task of collecting the debts. The data required for the collection will be communicated to the assigned legal person. The legal basis is Article 6 (1) (b) and Article 6 (1) (f) GDPR.
7. Processing during website usage
7.1 Data processing and logging during accesses from the internet
Your internet browser automatically transmits data to our web server for technical reasons when you access our website. The web server automatically saves a server log file of the transmitted data. For example, the name and URL of the retrieved data, IP address and date/time of the retrieval are collected. This data is processed to enable you to use the website, to ensure smooth operation of the website and to optimise the website.
We use technically necessary cookies (essential) so that we can provide the service you access in a secure, effective and user-friendly manner.
You can configure your browser in such a way that you only allow cookies in individual cases, activate the automatic deletion of cookies when you close your browser or exclude the acceptance of cookies in certain situations or generally.
You can use the browser setting “Do-Not-Track” if you do not want your activities to be recorded. If you activate this setting, no usage data concerning your visit will be stored.
7.3 Google Analytics
If you have given your consent, this website uses Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; (“Google”). Google Analytics uses “cookies”, text files which are stored on your computer and make it possible to analyse your use of the website.
As a rule, the information generated by the cookie about your use of this website will be transmitted to and stored by Google servers in the United States.
We use Google Signals. This allows Google Analytics to collect additional information about users who have personalized ads enabled (interests and demographics) and ads can be delivered to these users in cross-device remarketing campaigns.
Google Analytics has IP address anonymization enabled by default. If IP anonymisation is activated on this website, your IP address will be truncated beforehand by Google within Member States of the European Union or in the countries and territories of other signatories of the Agreement on the European Economic Area. Only in exceptional cases will your complete IP address be transferred to a Google server in the United States and shortened there.
On behalf of the operator of this website, Google will use this information to analyse your use of the website, to compile reports about website activities and to provide further services associated with website use and internet use for the website operator.
According to Google, Google will not associate the IP address transmitted by your browser within the framework of Google Analytics with any other data held by Google.
You can prevent the storage of cookies from the outset by setting your browser software accordingly. However, if you configure your browser to reject all cookies, this may result in a restriction of functionalities on this and other websites.
You can also prevent the collection of data generated by the cookie regarding your use of the website (including your IP address) to Google as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout
More information about data protection at Google is available at https://policies.google.com/privacy?hl=en&gl=en and https://policies.google.com/technologies/cookies?hl=en.
7.4 Microsoft Advertising
Microsoft Advertising is used for the purpose of optimizing the placement of advertisements. You can find more information about data protection at Microsoft in the Microsoft data protection information at https://privacy.microsoft.com/de-de/privacystatement.
We use the “ProductBoard” service provided by ProductBoard Inc, 612 Howard St., 4th Floor, San Francisco, CA 94105, USA, to collect ideas from users for product improvement. By giving us your message via ProductBoard, your data (such as e-mail address, name and other voluntarily provided data) will be transmitted to servers of ProductBoard Inc. and stored for us.
Further details and information on the specific data protection provisions of ProductBoard can be found at https://www.productboard.com/privacy-policy/2021-10-20/.
Our website uses YouTube for the incorporation of videos. YouTube is a service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). If you call up a page on our website containing such a feature, the data collected by Google will usually be sent to a server of Google LLC, USA and stored there. The content of the YouTube button is directly transmitted from Google to your browser, where it is incorporated into the website. We therefore have no influence over the scope of the data collected by Google with this feature, but assume that your IP address will also be included.
For more information on the purpose and scope of data collection, the further processing and use of information by Google, the rights you have in this regard and the privacy options available to you, please refer to Google’s data protection information concerning YouTube integration at https://policies.google.com/privacy?hl=en&gl=en.
If you are a YouTube member and do not wish for Google to use our internet presence as a way to collect details about you and to link this information with the membership data about you which Google has stored, then you must log out of YouTube before visiting our website.
7.7 Google Maps
On individual web pages, we use Google Maps, a service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), to display maps, locations and for route planning. By embedding Google Maps, your IP address is transmitted to Google and a cookie is stored. You can inform yourself at any time about the data processing by Google at http://www.google.de/intl/de/policies/privacy and object to it.
We use the Albacross service of Albacross Nordic AB (Kungsgatan 26, 111 35, Stockholm, Sweden) to identify visitors to our websites and to obtain information about the respective organization. When you visit our website, a cookie is stored on your computer. This analyzes surfing behavior by processing your IP address and other information. This allows us to determine to which organization your IP address belongs.
7.9 Google Tag Manager
We use Google Tag Manager, a service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), on our website in order to connect external web services to a website.
Google Tag Manager allows us to connect our website to other services, for example, Google Analytics, provided you have given your consent to the respective services on our site. In this instance, Google Tag Manager is only used for implementing the services in our website. No personal data is collected, stored or processed.
For more information on Google’s use policy for Google Tag Manager, please visit: https://www.google.com/intl/de/tagmanager/use-policy.html
7.10 Google Ads
We use the online advertising program “Google Ads” including conversion tracking (evaluation of user actions) on our website. Google conversion tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). If your habitual residence is in the European Economic Area or Switzerland, Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) will be the controller responsible for your data. Google Ireland Limited is therefore the Google-affiliated company responsible for processing your data and adhering to the applicable data protection laws.
When you click an ad delivered by Google, a cookie for conversion tracking is stored on your computer. These cookies have a limited period of validity, do not contain any personal data and are therefore not used for personal identification. If you visit certain pages on our website and the cookie has not yet expired, we and Google will be able to recognise that you have clicked the ad and proceeded to that page. Every Google Ads customer receives a different cookie. This means that there is no way that cookies can be tracked through the websites of Google Ads customers.
The information obtained using the conversion cookie is used to generate conversion statistics. This allows us to see the total number of users that have clicked one of our ads and proceeded to a page featuring a conversion tracking tag. However, we do not receive any information that can be used to personally identify users. Your data may be transmitted to the USA. You can disable personalised advertising in the advertising settings for Google. Instructions are available at https://support.google.com/ads/answer/2662922?hl=en.
We use the provider Intercom R&D Unlimited Company, 18-21 St. Stephen’s Green, Dublin 2, Ireland for product tours and for sending our messages in our software and when using the chat system on our website to provide information.
We transmit some of your information (such as email address and date of registration) to Intercom. Intercom collects publicly available contact information associated with you, such as company name and website URLs, for the purpose of improving your user experience.
For more information about Intercom’s privacy practices, please visit http://docs.intercom.io/privacy.
7.12 Borlabs Cookie
We use the consent management tool Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) when you visit our website. The tool allows you to give your consent to data processing activities via the website, in particular the setting of cookies. You can also use this tool to exercise your right to revoke permissions previously given.
The permissions you submitted when visiting the website are stored in the tool.
If you have given your consent via the consent management tool, you can revoke your consent at any time by accessing the settings and changing your selection there.
We offer you as an applicant the possibility to apply via an online application form. To provide the application form, we use the services of the personnel and applicant management software Personio of Personio GmbH, Rundfunkplatz 4, 80335, Munich, Germany.
If you apply via the form, the data entered (e.g. first and last name, contact data such as e-mail, as well as application documents) will be transmitted to Personio and stored for us.
Further details and information on Personio’s specific data protection provisions can be found at https://www.personio.de/datenschutzerklaerung/.
We use the service Brevo of Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany, for sending newsletters. Brevo is a service with which the newsletter dispatch can be organized and analyzed. The data you enter for the purpose of receiving newsletters (e.g. e-mail address) is stored on the servers of Sendinblue GmbH.
Our newsletters sent with Brevo enable us to analyze the behavior of the recipients of the newsletters. Among other things, this allows us to analyze how many recipients have opened the newsletter message and how often which link in the newsletter was clicked. All links in the email are so-called tracking links, which can be used to count your clicks.
If you do not want any analysis by Brevo, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. Furthermore, you can also revoke your consent at any time with effect for the future by sending an e-mail to the address stored in this declaration (see above).
The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of Sendinblue GmbH after you unsubscribe from the newsletter.
7.15 Google account registration
We allow our customers in our software to log in to their Google account to access their data. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Through the registration and subsequent confirmation of access, personal data may be transmitted from us to Google and from Google to us (e.g. IP address).
8. Social media presence
8.1 Facebook and Instagram
We are represented with company pages on Facebook and Instagram. Facebook and Instagram are websites provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (“Meta”). The information collected automatically by Meta about your use of our online presence is generally transferred to a server of Meta Platforms, Inc., USA and stored there.
Certain information concerning you is processed when you visit our Facebook or Instagram pages. Meta is the sole controller for this processing of personal data. For more details about the processing of personal data by Meta, please visit https://www.facebook.com/privacy/explanation.
Meta provides statistics in anonymised form that gives us insights into actions taken by individuals on our page (so-called “page insights”). These page insights are created on the basis of specific information about individuals who have visited our page. This processing of personal data is carried out by Meta and ourselves as joint controllers. For details about the processing of personal data in order to create page insights and the agreement concluded between us and Meta, please visit https://www.facebook.com/legal/terms/information_about_page_insights_data.
LinkedIn is a website provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). The information collected automatically by LinkedIn about your use of our online presence on LinkedIn is generally transferred to a server of LinkedIn Corporation, USA and stored there.
Certain information concerning you is processed when you visit our LinkedIn company page. LinkedIn is the sole controller for this processing of personal data. For more details about the processing of personal data by LinkedIn, please visit https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy.
LinkedIn provides statistics in anonymised form that give us insights into actions taken by individuals on our LinkedIn page (so-called “page insights”). These page insights are created on the basis of specific information about individuals who have visited our page. This processing of personal data is carried out by LinkedIn and ourselves as joint controllers. For details about the processing of personal data in order to create page insights and the agreement concluded between us and LinkedIn, please visit https://legal.linkedin.com/pages-joint-controller-addendum.
9. Consent clause
You may provide your express consent to the receipt of newsletters as outlined below and this consent will then be logged. We will keep the content of consent available for retrieval at any time. Of course, you can object to the use of your data for the following purposes at any time or revoke your consent.
10. Provision of data
In the context of the business relationship with you, you must provide such personal data that is required for the establishment, implementation, termination and fulfilment of the associated contractual obligations. You are also required to provide personal data that we are legally obliged to collect. Generally speaking, we will not be able to conclude, implement or terminate a contract with you without this data.
11. Your rights as a data subject
Every data subject has the right to information according to Article 15 GDPR, the right to rectification according to Article 16 GDPR, the right to erasure according to Article 17 GDPR, the right to the restriction of processing according to Article 18 GDPR, the right to object from Article 21 GDPR and the right to data portability from Article 20 GDPR. The restrictions under Sections 34 and 35 BDSG apply to the right to information and the right to erasure.
Finally, you have a right to lodge a complaint with the data protection supervisory authority responsible for you.
Information about your right to object pursuant to Article 21 GDPR
Insofar as we process personal data to protect our legitimate interests that prevail in the process of balancing interests, you as a data subject can object to this processing at any time. You can also exercise this right to object if processing takes place for purposes of direct marketing. If processing takes place for other purposes, you have the right to object for reasons relating to your particular situation.
If you file an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for its processing, which override the interests, rights and freedoms of the data subject or such processing is used for the establishment, exercise or defence of legal claims.
However, this does not apply in the case of processing for purposes of direct marketing. If you object to data processing for purposes of direct marketing, we will no longer process your personal data for these purposes.
You can revoke consent issued to us previously for the processing of personal data at any time. This also applies to the revocation of declarations of consent that were issued to us before the EU General Data Protection Regulation came into force, i.e. prior to 25 May 2018. Please note that such revocation only applies to the future. Processing that takes place prior to consent being issued is not affected by such.
Please contact our data protection officer if you have any questions concerning the processing of your personal data or your aforementioned rights.
Last revised: August 2023
Our template for a Data Processing Agreement is available here.