Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter referred to as "data") that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and particularly on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific.

As of: March 19, 2026

Preamble
Responsible Party
Contact Data Protection Officer
Overview of Processing Activities
Relevant Legal Bases
Security Measures
Transmission of Personal Data
International Data Transfers
General Information on Data Storage and Deletion
Rights of Affected Persons
Provision of the Online Offer and Web Hosting
Use of Cookies
Blogs and Publication Media
Contact and Inquiry Management
Artificial Intelligence (AI)
Video Conferences, Online Meetings, Webinars, and Screen Sharing
Cloud Services
Newsletters and Electronic Notifications
Web Analysis, Monitoring, and Optimization
Online Marketing
Presences in Social Networks (Social Media)
Plug-ins and Embedded Functions as well as Content
Management, Organization, and Support Tools
Processing of Data in Employment Relationships
Application Procedures
Changes and Updates
Definitions

Responsible Party

LEAN-CODERS GmbH c/o Ms. Roberta Ott

Hainburger Strasse 33

1030 Vienna

Authorized Representatives: Stefan Wöhrer

Email Address: stefan.woehrer@lean-coders.at

Imprint: https://lean-coders.at/imprint

Contact Data Protection Officer

Roberta Ott

roberta.ott@lean-coders.at

Overview of Processing Activities

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

Types of Processed Data

Inventory data, employee data, payment data, location data, contact data, content data, contract data, usage data, meta-, communication- and procedural data, social data, applicant data, image and/or video recordings, audio recordings, contact information (Facebook), event data (Facebook), log data, performance and behavior data, working time data, salary data

Special Categories of Data

Health data, religious or philosophical beliefs, union membership

Categories of Affected Persons

Employees, interested parties, communication partners, users, applicants, business and contractual partners, depicted persons, third parties

Purposes of Processing

Provision of contractual services and fulfillment of contractual obligations, communication, security measures, direct marketing, reach measurement, tracking, office and organizational procedures, remarketing, conversion measurement, audience formation, organizational and administrative procedures, application procedures, content delivery network (CDN), feedback, marketing, profiles with user-related information, provision of our online offer and user-friendliness, establishment and execution of employment relationships, IT infrastructure, public relations, business processes and economic procedures, artificial intelligence (AI).

Relevant Legal Bases

Relevant 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 provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. If, in individual cases, more specific legal bases are relevant, we will inform you of these in the privacy policy.

Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The affected person has given their consent to the processing of their personal data for a specific purpose or purposes.

Contract Fulfillment and Pre-Contractual Inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the fulfillment of a contract to which the affected person is a party, or for carrying out pre-contractual measures at the request of the affected person.

Legal Obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary to fulfill a legal obligation to which the responsible party is subject.

Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - The processing is necessary to protect the legitimate interests of the responsible party or a third party, provided that the interests, fundamental rights, and freedoms of the affected person, which require the protection of personal data, do not override those interests.

Application Procedures as Pre-Contractual or Contractual Relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) - If, in the context of the application procedure, special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g., health data, such as disability status or ethnic origin) are requested from applicants, so that the responsible party or the affected person can exercise their rights under labor law and social security and social protection law, and fulfill their related obligations, their processing is carried out according to Art. 9 para. 2 lit. b. GDPR, in the case of protecting vital interests of applicants or other persons according to Art. 9 para. 2 lit. c. GDPR, or for purposes of health care or occupational medicine, for assessing the employee's work ability, for medical diagnostics, care or treatment in the health or social sector, or for managing systems and services in the health or social sector according to Art. 9 para. 2 lit. h. GDPR. In the case of voluntary consent to the communication of special categories of data, their processing is based on Art. 9 para. 2 lit. a. GDPR.

Processing of Special Categories of Personal Data in Relation to Health Care, Employment, and Social Security (Art. 9 para. 2 lit. h) GDPR) - The processing is necessary for purposes of health care or occupational medicine, for assessing the employee's work ability, for medical diagnostics, care or treatment in the health or social sector, or for managing systems and services in the health or social sector based on Union law or the law of a member state or due to a contract with a health professional.

National Data Protection Regulations in Austria:* In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Austria. This includes, in particular, the Federal Act on the Protection of Natural Persons in the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains specific provisions regarding the right to information, the right to rectification or deletion, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated decision-making in individual cases.

Note on the Applicability of GDPR and Swiss Data Protection Act:* This privacy notice serves both to provide information under the Swiss Data Protection Act and the General Data Protection Regulation (GDPR). Therefore, please note that due to the broader geographical application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss Data Protection Act "processing" of "personal data", "overriding interest" and "particularly sensitive personal data", the terms used in the GDPR "processing" of "personal data" as well as "legitimate interest" and "special categories of data" are used. However, the legal significance of the terms will continue to be determined within the scope of the applicability of the Swiss Data Protection Act according to the Swiss Data Protection Act.

Security Measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, in accordance with legal requirements, considering 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 severity of the threat to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transmission, availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of affected rights, the deletion of data, and responses to data breaches. Additionally, we consider the protection of personal data already during 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 through TLS/SSL Encryption Technology (HTTPS): To protect users' data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and encrypted.

Transmission of Personal Data

In the context of our processing of personal data, it may occur that this data is transmitted to other entities, companies, legally independent organizational units, or persons. Recipients of this data may include service providers tasked with IT functions 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 transmit data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the context of using third-party services or disclosing or transmitting data to other persons, entities, or companies (which is evident from the postal address of the respective provider or when the privacy policy explicitly refers to the data transfer to third countries), this is always done in accordance with legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by an adequacy decision from the EU Commission dated July 10, 2023. Additionally, we have entered into 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 protection ensures comprehensive safeguarding of your data: The DPF serves as the primary layer of protection, while the standard contractual clauses provide additional security. Should there be changes to the DPF framework, the standard contractual clauses act as a reliable fallback option. This way, we ensure that your data remains adequately protected even in the event of political or legal changes.

For each service provider, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. You can find more information about the DPF and a list of certified companies on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, especially standard contractual clauses, explicit consents, or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the EU Commission's information offerings at: 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 consents are revoked or no further legal grounds for processing exist. This applies in cases where the original purpose of processing 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 reasons or whose retention is necessary for legal prosecution 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 specifically applies to certain processing processes.

In cases where multiple retention periods or deletion deadlines are specified for a date, the longest period shall apply. Data that is retained not for the originally intended purpose but due to legal requirements or other reasons will be processed solely for the reasons justifying their retention.

Retention and deletion of data: The following general periods apply according to Austrian law for the retention and archiving of personal data, as far as these are necessary to fulfill legal obligations or to safeguard legitimate interests:

7 years Personal data processed in connection with tax-relevant business documents will be retained for a period of seven years in accordance with § 132 BAO and §§ 190–212 UGB. This includes, in particular, books and records, annual financial statements, inventories, management reports, opening balances, booking documents, invoices, as well as received and sent commercial or business letters and other documents relevant for tax assessment. The period begins at the end of the calendar year for which the last entry was made and may be extended as long as the documents are relevant for pending tax proceedings.
3 years Data required for asserting, exercising, or defending warranty, compensation, or other contractual claims will be stored for the duration of the applicable statutory limitation period. This is regularly three years according to § 1489 ABGB, unless longer statutory retention obligations exist.

Rights of the data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, particularly arising from Articles 15 to 21 of the GDPR:

Right to object: You have the right to object at any time to the processing of personal data concerning you, which is based on Article 6(1)(e) or (f) GDPR, for reasons relating to your particular situation; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing.

Right of withdrawal for consents: You have the right to withdraw consents given at any time.

Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.

Right to rectification: You have the right to request the completion of your personal data or the rectification of inaccurate personal data concerning you in accordance with legal requirements.

Right to deletion and restriction of processing: You have the right to request the immediate deletion of personal data concerning you or, alternatively, to request a restriction of the processing of your data in accordance with legal requirements.

Right to data portability: You have the right to receive personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format or to request the transmission to another controller in accordance with legal requirements.

Complaint to a supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, particularly with a supervisory authority in the member state where you usually reside, the supervisory authority of your workplace, or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Provision of the online offer and web hosting

We process user data to provide 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.

Processed data types: Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); log data (e.g., log files regarding logins or data retrieval or access times). Content data (e.g., textual or visual messages and posts as well as related information, such as authorship or creation time).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing and legitimate interests: Provision of our online offer and user-friendliness; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Content Delivery Network (CDN).

Retention and deletion: Deletion according to the information provided in the section "General information on data storage and deletion."

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

Further notes on processing processes, procedures, and services:*

Provision of online offer on rented storage space: To provide our online offer, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also referred to as "web hoster"); Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files." Server log files may include the address and name of the retrieved websites and files, date and time of retrieval, transmitted data volumes, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure server load and stability; Legal bases: Legitimate interests (Article 6(1)(f) GDPR). Deletion of data: Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.

Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that helps deliver content of an online offer, especially large media files, such as graphics or program scripts, faster and more securely using regionally distributed and internet-connected servers; Legal bases: Legitimate interests (Article 6(1)(f) GDPR).

Hetzner: Services in the field of providing IT infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.hetzner.com; Privacy policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data processing agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.

Cloudflare: Content Delivery Network (CDN) service that helps deliver content of an online offer, especially large media files, such as graphics or program scripts, faster and more securely using regionally distributed and internet-connected servers; Service provider: Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA; Legal bases: Legitimate interests (Article 6(1)(f) GDPR); Website: https://www.cloudflare.com; Privacy policy: https://www.cloudflare.com/privacypolicy/; Data processing agreement: https://www.cloudflare.com/cloudflare-customer-dpa/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.cloudflare.com/cloudflare-customer-scc/).

Use of cookies

The term "Cookies" refers to functions that store and read information on users' devices. Cookies can be used for various purposes, such as functionality, security, and convenience of online services, as well as for analyzing visitor traffic. We use cookies in accordance with legal regulations. If necessary, we obtain users' consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes storing settings and ensuring the functionality and security of our online services. Consent can be revoked at any time. We clearly inform about the scope and which cookies are used.

Notes on data protection legal bases:* 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 duration:* Regarding storage duration, the following types of cookies are distinguished:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service 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. Additionally, user data collected via cookies can be used for reach measurement. If we do not provide explicit information to users about the type and storage duration of cookies (e.g., during consent collection), they should assume that these are permanent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-out):* Users can revoke their given consents at any time and also declare an objection to processing in accordance with legal requirements, including through their browser's privacy settings.

Processed data types: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions).

Affected persons: Users (e.g., website visitors, users of online services).

Purposes of processing and legitimate interests: Provision of our online services and user-friendliness.

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

Further notes on processing processes, procedures, and services:*

Processing of cookie data based on consent: We use a consent management solution that obtains users' consent for the use of cookies or for the procedures and providers mentioned in the consent management solution. This process serves to obtain, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies that are used to store, read, and process information on users' devices. In this process, users' consents for the use of cookies and the associated processing of information, including the specific processes and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid repeated queries and to provide proof of consent in accordance with legal requirements. The storage is done server-side and/or in a cookie (so-called opt-in cookie) or using similar technologies to assign the consent to a specific user or their device. If there are no specific details about the providers of consent management services, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details about the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Cookie Opt-Out: In the footer of our website, you will find a link through which you can change your cookie settings and revoke corresponding consents.

Contact and inquiry management

When contacting us (e.g., by post, contact form, email, phone, or via social media) and in the context of existing user and business relationships, the details of the inquiring persons are processed as far as necessary to respond to contact inquiries and any requested actions.

Processed data types: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as authorship or creation time). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Affected persons: Communication partners.
Purposes of processing and legitimate interests: Communication; organizational and administrative processes; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion."
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Fulfillment of contracts and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further notes on processing processes, procedures, and services:*
Contact form: When contacting us via our contact form, email, or other communication channels, we process the personal data provided to us to respond to and handle the respective inquiry. This typically includes information such as name, contact details, and any additional information provided that is necessary for appropriate handling. We use this data solely for the stated purpose of contact and communication; Legal bases: Fulfillment of contracts and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Artificial Intelligence (AI)

We use Artificial Intelligence (AI), processing personal data. The specific purposes and our interest in using AI are mentioned below. By AI, we mean a "AI system" as defined in Article 3 No. 1 of the AI Regulation, a machine-based system designed for varying degrees of autonomous operation, which can be adaptable after its introduction and produces results such as predictions, content, recommendations, or decisions from the inputs received, which can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include both specific regulations for Artificial Intelligence and data protection provisions. We particularly adhere to the principles of legality, transparency, fairness, human control, purpose limitation, data minimization, integrity, and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This can either be the consent of the affected persons or a legal permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable regulations. We also observe our obligations when using or operating the acquired AI services. The processing of personal data by us and the AI providers occurs solely based on consent or legal authorization. We place particular emphasis on transparency, fairness, and maintaining human control over AI-supported decision-making processes.

To protect the processed data, we implement appropriate and robust technical and organizational measures. These ensure the integrity and confidentiality of the processed data and minimize potential risks. Through regular reviews of the AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

Processed data types: Content data (e.g., textual or visual messages and posts, as well as related information such as authorship or creation time). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions).
Affected persons: Users (e.g., website visitors, users of online services). Third parties.
Purposes of processing and legitimate interests: Artificial Intelligence (AI); office and organizational processes; provision of our online services and user-friendliness. IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion."
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
ChatGPT: AI-based service designed to understand and generate natural language and associated inputs and data, analyze information, and make predictions ("AI", meaning "Artificial Intelligence", is to be understood in the applicable legal sense); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/de-DE/chatgpt/overview/; Privacy policy: https://openai.com/de-DE/policies/privacy-policy/. Right to object (Opt-Out): https://privacy.openai.com/policies?modal=select-subject.
OpenAI API: An API (Application Programming Interface) for Artificial Intelligence that provides developers access to language and image models like GPT and DALL·E. It enables the integration of functions such as automatic text generation, natural language processing (NLP), translation, code generation, image creation, and image analysis into their own applications. Complex AI functions can be integrated and processes automated through standardized interfaces; Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/; Privacy policy: https://openai.com/de/policies/eu-privacy-policy; Data processing agreement: https://openai.com/policies/data-processing-addendum; Basis for third country transfers: Standard contractual clauses (https://openai.com/policies/data-processing-addendum). Right to object (Opt-Out): https://privacy.openai.com/policies?modal=select-subject.
Claude API: AI-powered service designed to understand and generate natural language and related inputs, analyze information, and make predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the applicable legal sense of the term). The provision of AI services includes the processing (including collection, storage, organization, and structuring) of personal data within a natural language-based machine learning process; conducting measures to verify and maintain the quality of the services; identifying and correcting errors that may impair the intended functionality, as well as supporting the security and integrity of the AI services; Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.anthropic.com/; Privacy policy: https://www.anthropic.com/legal/privacy; Data processing agreement: https://www.anthropic.com/legal/data-processing-addendum. Basis for third country transfers: Standard contractual clauses (https://www.anthropic.com/legal/data-processing-addendum).
Claude API: Interface access (so-called "API") to AI-based services designed to understand and generate natural language and related inputs, analyze information, and make predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the applicable legal sense of the term). The provision of AI services includes the processing (including collection, storage, organization, and structuring) of personal data as part of a natural language-based machine learning process; conducting activities to verify or maintain the quality of the services; identifying and correcting errors that may impair the existing intended functionality, as well as supporting the security and integrity of the AI services; Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.anthropic.com/; Privacy policy: https://www.anthropic.com/legal/privacy; Data processing agreement: https://www.anthropic.com/legal/data-processing-addendum. Basis for third country transfers: Standard contractual clauses (https://www.anthropic.com/legal/data-processing-addendum).

Video conferences, online meetings, webinars, and screen sharing

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

Data processed by conference platforms:* In the context of participating in a conference, the conference platforms process the personal data of participants as mentioned below. The scope of processing depends on which data are required for a specific conference (e.g., providing access credentials or real names) and which optional information is provided by the participants. In addition to processing for conducting the conference, the participants' data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (email address, phone number), access credentials (access codes or passwords), profile pictures, information about job position/function, the IP address of the internet access, information about the participants' devices, their operating system, the browser and its technical and language settings, information about the content of communication processes, i.e., inputs in chats as well as audio and video data, as well as the use of other available functions (e.g., polls). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users on the conference platforms, additional data may be processed according to the agreement with the respective conference provider.
Logging and recordings:* If text inputs, participation results (e.g., from polls), as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance, and they will be asked for consent where necessary.
Data protection measures for participants:* Please refer to the details of the processing of your data by the conference platforms in their privacy notices and select the optimal security and privacy settings for you within the settings of the conference platforms. Additionally, please ensure data and personal protection in the background of your recording during a video conference (e.g., by informing housemates, locking doors, and using, as far as technically possible, the function to blur the background). Links to conference rooms and access credentials must not be shared with unauthorized third parties.
Notes on legal bases:* If we also process users' data in addition to the conference platforms and ask users for their consent to use the conference platforms or certain functions (e.g., consent to record conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g., in participant lists, in case of processing discussion results, etc.). Otherwise, users' data are processed based on our legitimate interests in efficient and secure communication with our communication partners.
Types of processed data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or creation time); usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions); image and/or video recordings (e.g., photographs or video recordings of a person); audio recordings. Log data (e.g., log files regarding logins or data retrieval or access times).
Affected persons: Communication partners; users (e.g., website visitors, users of online services). Depicted persons.
Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion."
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
Microsoft Teams: Used for conducting online events, conferences, and communication with internal and external participants. Voice transmission, direct messaging, group communication, and collaboration features are utilized; processed data includes name, business contact details, work profile, participation, and content (audio/video, speech, chat, files, speech transcription) for purposes and interests in efficiency and productivity increases, cost efficiency, flexibility, mobility, improved communication, IT security, use of a central platform, and business processing by Microsoft. Audio signals are generally not stored unless recording is activated. Meeting and conference recordings are typically stored for 90 days unless a different duration is specified. Chat and file contents are stored according to the guidelines set by the administrator or user; automatic deletion is not preset. Channels must be renewed every 180 days; otherwise, content will be deleted. Additionally, system-generated log, diagnostic, and metadata are processed, and diagnostic data is collected for product stability, security, and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: Data Privacy Framework (DPF), Standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).

Cloud services

We use software services accessible over the internet and executed on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for storing and managing content (e.g., document storage and management, sharing documents, content, and information with specific recipients, or publishing content and information).

In this context, personal data may be processed and stored on the providers' servers, as far as they are part of communication processes with us or otherwise processed by us as outlined in this privacy policy. This data may particularly include master data and contact data of users, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and service optimization.

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

Types of processed data: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as authorship details or creation time); usage data (e.g., page views and duration, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Affected persons: Interested parties; communication partners; business and contractual partners. Users (e.g., website visitors, online service users).
Purposes of processing and legitimate interests: Office and organizational procedures; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Provision of our online offerings and user-friendliness.
Storage and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures, and services:*
Microsoft 365 and Microsoft Cloud Services: Provision of applications, protection of data and IT systems, and use of system-generated log, diagnostic, and metadata for contract execution by Microsoft. Processed data includes contact data (name, email address), content data (files, comments, profiles), software setup and inventory data, device connectivity and configuration data, work interactions (badge swipe), and log and metadata. Processing occurs for purposes of efficiency and productivity improvements, cost efficiency, flexibility, mobility, improved communication, integration of Microsoft services, IT security, and business operations of Microsoft. Data retention is governed by the respective documents and company policies, with Defender (protection of data and IT systems) up to 12 months, and print management 10 days. Additionally, diagnostic data is collected for product stability and improvement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://microsoft.com/en-us; Privacy policy: https://privacy.microsoft.com/en-us/privacystatement, Security notices: https://www.microsoft.com/en-us/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Microsoft Azure: Services in the field of providing IT infrastructure and related services (e.g., storage space and/or computing power); Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://azure.microsoft.com; Privacy policy: https://privacy.microsoft.com/en-us/privacystatement; Data processing agreement: https://azure.microsoft.com/en-us/support/legal/. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://azure.microsoft.com/en-us/support/legal/).

Online game and contest "TRICK OR LEAN"

What data: If you participate in our online game "TRICK OR LEAN – Pumpkins in the air, Candy everywhere," we process your email address, the display name you choose, and your game results (score, time). In case of winning, we additionally process your name and, if necessary for shipping, your postal address.

Purpose: Conducting the game and contest, displaying on the scoreboard, determining and notifying the winners, handing over the prizes, and protecting against manipulation.

Legal basis: Art. 6 para. 1 lit. b GDPR (conducting the contest according to the terms of participation). To defend against manipulation and abuse, we rely on our legitimate interest (Art. 6 para. 1 lit. f GDPR).

Scoreboard: Your display name and score are visible on the public scoreboard for all visitors of the game page. You choose the display name yourself; you do not have to use your real name. Your email address will never be published.

Recipients and hosting: The game is operated by us and hosted on our servers at Hetzner Online GmbH, Germany (see section "Provision of the online offering and web hosting"). Disclosure to third parties occurs only as necessary for the delivery of a prize (e.g., to a courier service). There is no transmission to third countries.

Storage duration: We delete all data collected during the game after the game ends on November 15, 2026, as soon as the prizes are handed over, but no later than December 31, 2026. The scoreboard will be removed at the same time.

Newsletter: If you additionally subscribed to our newsletter during registration, the section "Newsletter and electronic notifications". This consent is voluntary and not a prerequisite for participation.

Your rights: You can end your participation at any time and request the deletion of your data, e.g., by email to roberta.ott@lean-coders.at. This will also end your participation in the contest. Your further rights and your right to complain to the data protection authority can be found in the section "Rights of the affected persons".

Web analysis, monitoring, and optimization

Web analysis (also referred to as "reach measurement") serves to evaluate the visitor flows of our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, determine when our online offering or its functions or content are most frequently used or invite reuse. We can also track which areas need optimization.

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

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, can be created for these purposes, and information can be stored and then read in a browser or on an end device. The collected data includes, in particular, visited websites and used elements, 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.

Furthermore, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. 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 procedures.

Notes on legal bases: If we ask users for their consent to use 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 regarding the use of cookies in this privacy policy.

Types of processed data: Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); content data (e.g., textual or visual messages and posts, as well as related information such as authorship or creation time). Event data (Facebook) ("Event data" refers to information sent to the provider Meta via Meta-Pixel (whether through apps or other channels) that relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. The processing of event data aims to create target audiences for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as written comments, login information, or contact details like names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the resulting target audiences disappear with the deletion of our Meta user accounts.).
Affected persons: Users (e.g., website visitors, online service users).
Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creating user profiles); provision of our online offerings and user-friendliness; tracking (e.g., interest-/behavior-based profiling, use of cookies); conversion measurement (measuring the effectiveness of marketing measures); audience formation. Marketing.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods can be stored on users' devices for a period of two years.).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
umami: Web analysis, reach measurement, and analysis of user behavior; occurs pseudonymously and without the creation of user profiles; all user data is stored anonymously, meaning without personal data and without the use of cookies or comparable persistent online identifiers; Service provider: Execution on servers and/or computers under its own data protection responsibility; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://umami.is. Privacy policy: https://umami.is/privacy.
LinkedIn Insight Tag: Code that is loaded when a user visits our online offering and tracks the user's behavior and conversions, storing it in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie\_policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Meta-Pixel and audience formation (Custom Audiences): With the help of the Meta-Pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), the company Meta can determine the visitors of our online offering as a target group for displaying ads (so-called "Meta-Ads"). Accordingly, we use the Meta-Pixel to display the Meta-Ads we run only to users on Meta platforms and within the services of partners cooperating with Meta (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown interest in our online offering or exhibit certain characteristics (e.g., interest in specific topics or products evident from the visited websites) that we transmit to Meta (so-called "Custom Audiences"). With the help of the Meta-Pixel, we also want to ensure that our Meta-Ads match the potential interest of users and do not appear intrusive. Furthermore, with the help of the Meta-Pixel, we can track the effectiveness of Meta-Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta-Ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU\_data\_transfer\_addendum); Further information: Event data of users, i.e., behavioral and interest information, is processed for the purposes of targeted advertising and audience formation based on the agreement on joint responsibility ("Controller Addendum", https://www.facebook.com/legal/controller\_addendum) The joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly regarding the transmission of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
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 unique data such as names or email addresses. It serves to assign analysis information to an end device to recognize which content users have accessed within one or multiple usage sessions, which search terms they have used, have re-accessed, or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers.

Pseudonymous profiles of users are created with information from the use of various devices, where cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides 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, the IP address data is used solely for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are conducted on EU-based servers before the traffic is forwarded for processing to Analytics servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. 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); Right to object (Opt-Out): Opt-Out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for displaying ads: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).

Online marketing

We process personal data for the purpose of online marketing, which may include the marketing of advertising spaces or the display of advertising and other content (collectively referred to as "content") based on potential user interests, as well as measuring their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar methods are used to store the relevant information about the user for displaying the aforementioned content. This may include viewed content, visited websites, used online networks, as well as communication partners and technical information such as the browser used, the computer system used, and information about usage times and utilized functions. If users have consented to the collection of their location data, this may also be processed.

Additionally, users' IP addresses are stored. However, we use available IP masking methods (i.e., pseudonymization by truncating the IP address) for user protection. Generally, no clear data of users (such as email addresses or names) is stored in the context of online marketing processes, but pseudonyms. This means that we, as well as the providers of online marketing processes, do not know the actual user identity, but only the information stored in their profiles.

The statements in the profiles are usually stored in cookies or via similar methods. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

In exceptional cases, it is possible to assign clear data to profiles, primarily when users are, for example, members of a social network whose online marketing methods we employ, and the network connects user profiles with the aforementioned information. Please note that users may make additional agreements with the providers, such as consent during registration.

In general, we only have access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, a contract conclusion with us. Conversion measurement is used solely for the success analysis of our marketing measures.

Unless otherwise stated, please assume that cookies used are stored for a period of two years.

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 regarding the use of cookies in this privacy policy.
Notes on revocation and objection:*

We refer to the privacy notices of the respective providers and the objection options provided for the providers (so-called "Opt-Out"). If no explicit opt-out option is provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offerings. Therefore, we also recommend the following opt-out options, which are summarized for respective areas:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://youradchoices.ca/.

c) USA: https://optout.aboutads.info/.

d) Cross-border: https://optout.aboutads.info.

Processed data types: Content data (e.g., textual or visual messages and posts as well as related information, such as authorship or creation time); Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); Event data (Facebook) ("Event data" refers to information sent to the provider Meta via Meta-Pixel (whether through apps or other channels) that relates to individuals or their actions. This data includes details about website visits, interactions with content and features, app installations, and product purchases. The processing of event data aims to create target audiences for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as written comments, login information, or contact information like names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the resulting target audiences disappear with the deletion of our Meta user accounts.); Contact information (Facebook) ("Contact information" refers to data that clearly identifies affected individuals, such as names, email addresses, and phone numbers, which can be transmitted to Facebook, e.g., via Facebook Pixel or upload for matching purposes to create Custom Audiences. After matching for audience creation, the contact information is deleted).
Affected individuals: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest-/behavior-based profiling, use of cookies); Conversion measurement (measuring the effectiveness of marketing measures); Audience creation; Marketing; Profiles with user-related information (creating user profiles); Providing our online offerings and user-friendliness. Remarketing.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users' devices for a period of two years.).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
Meta-Pixel and audience creation (Custom Audiences): With the help of the Meta-Pixel (or similar functions for transmitting event data or contact information via interfaces in apps), the company Meta can determine the visitors of our online offerings as a target group for displaying ads (so-called "Meta-Ads"). Accordingly, we use the Meta-Pixel to show the Meta-Ads we run only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown interest in our online offering or who exhibit certain characteristics (e.g., interest in specific topics or products evident from the visited websites) that we transmit to Meta (so-called "Custom Audiences"). With the help of the Meta-Pixel, we also want to ensure that our Meta-Ads match the potential interests of users and do not appear intrusive. Furthermore, with the help of the Meta-Pixel, we can track the effectiveness of the Meta-Ads for statistical and market research purposes by seeing if users were redirected to our website after clicking on a Meta-Ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU\_data\_transfer\_addendum); Further information: Event data of users, i.e., behavioral and interest information, is processed for the purposes of targeted advertising and audience creation based on the agreement on joint responsibility ("Controller Addendum", https://www.facebook.com/legal/controller\_addendum) The joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly concerning the transmission of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Extended matching for the Meta-Pixel: In addition to processing event data in the context of using the Meta-Pixel (or similar functions, e.g., in apps), contact information (person-identifying data, such as names, email addresses, and phone numbers) is also collected by Meta within our online offerings or transmitted to Meta. The processing of contact information serves to create target audiences (so-called "Custom Audiences") for displaying content and advertising information tailored to the presumed interests of users. The collection, transmission, and matching with data available at Meta do not occur in plain text but as so-called "hash values," i.e., mathematical representations of the data (this method is used, for example, in password storage). After matching for audience creation, the contact information is deleted; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Privacy policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU\_data\_transfer\_addendum). Further information: https://www.facebook.com/legal/terms/data\_security\_terms.
Meta - Audience creation via data upload: Creating target audiences for marketing purposes - We transmit contact information (names, email addresses, and phone numbers) in list form to Meta for the purpose of creating target audiences (so-called "Custom Audiences") for displaying content and advertising information tailored to the presumed interests of users. The transmission and matching with data available at Meta do not occur in plain text but as so-called "hash values," i.e., mathematical representations of the data (this method is used, for example, in password storage). After matching for audience creation, the contact information is deleted; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU\_data\_transfer\_addendum).
Google Ad Manager: We use the service "Google Ad Manager" to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Ad Manager is characterized by displaying ads in real-time based on presumed user interests. This allows us to show ads for our online offering to users who may have a potential interest in our offering or who have previously shown interest, as well as to measure the success of the ads; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms. if Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third-country data transfers: https://business.safety.google/adsprocessorterms.
Google Ads and conversion measurement: Online marketing methods for placing content and ads within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.), so that they are shown to users who have a presumed interest in the ads. Additionally, we measure the conversion of the ads, i.e., whether users interacted with the ads and utilized the advertised offers (so-called conversions). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that adds users who utilize an online service to a pseudonymous remarketing list, allowing ads to be shown to users based on their visit to the online service on other online offerings; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF); Further information: Types of processing and processed data: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
LinkedIn Insight Tag: Code that loads when a user visits our online offering and tracks the user's behavior and conversions, storing them in a profile (possible use cases: measuring campaign performance, optimizing ad delivery, building custom and similar audiences); Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie\_policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
LinkedIn Ads: Displaying ads within the LinkedIn platform and evaluating ad results; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://business.linkedin.com/de-de/marketing-solutions/ads; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://www.linkedin.com/legal/l/dpa; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://de.linkedin.com/legal/l/dpa); Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further information: https://legal.linkedin.com/dpa.

Presences in social networks (Social Media)

We maintain online presences within social networks and process user data in this context to communicate with users active there or to provide information about us.

We would like to point out that user data may be processed outside the European Union. This can pose risks for users, as it may make the enforcement of user rights more difficult.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. The latter may then be used to display ads within and outside the networks that presumably match users' interests. Therefore, cookies are usually stored on users' computers, which store usage behavior and user interests. Additionally, data may also be stored in usage profiles independently of the devices used by users (especially if they are members of the respective platforms and logged in there).

For a detailed presentation of the respective processing forms and the options to object (Opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

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

Processed data types: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as authorship or creation time). Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Communication; feedback (e.g., collecting feedback via online forms). Public relations.
Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion."
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
Instagram: Social network that allows sharing photos and videos, commenting and favoriting posts, sending messages, and subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
Facebook Pages: Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page ("fan page"). This includes particularly information about user behavior (e.g., viewed or interacted content, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). More details can be found in the Facebook data policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations through the service "Page Insights," which give insights into how people interact with our page and its content. The basis for this is an agreement with Facebook ("Information on Page Insights": https://www.facebook.com/legal/terms/page\_controller\_addendum), which regulates security measures and the exercise of affected rights. Further information can be found here: https://www.facebook.com/legal/terms/information\_about\_page\_insights\_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (especially information, deletion, objection, complaint to a supervisory authority) remain unaffected. The joint responsibility is limited solely to the collection of data by Meta Platforms Ireland Limited (EU). For further processing, including possible transmission to Meta Platforms Inc. in the USA, only Meta Platforms Ireland Limited is responsible; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU\_data\_transfer\_addendum).
LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of data from visitors 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. Additionally, details about the devices used are collected, 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. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn's privacy notices: https://www.linkedin.com/legal/privacy-policy.

We have entered into a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum", https://legal.linkedin.com/pages-joint-controller-addendum), which particularly regulates the security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of affected individuals (i.e., users can direct requests for information or deletion directly to LinkedIn). The rights of users (especially the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility 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 solely the responsibility of LinkedIn Ireland Unlimited Company, particularly regarding the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://legal.linkedin.com/dpa). Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

X: Social network; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com. Privacy policy: https://x.com/de/privacy.
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Right to object (Opt-Out): https://myadcenter.google.com/personalizationoff.

Plug-ins and embedded functions as well as content

We integrate functional and content elements into our online offering, sourced from the servers of their respective providers (hereinafter referred to as "third parties"). This may include graphics, videos, or maps (hereinafter collectively referred to as "content").

The integration always requires that the third-party providers of this content process the users' IP addresses, as they could not send the content to their browsers without the IP address. The IP address is thus necessary for displaying this content or functions. We strive to use only those contents whose respective providers apply the IP address solely for delivering the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. Through the "pixel tags," information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the users' devices and may contain technical information about the browser and operating system, referring websites, visit times, and other details about the use of our online offering, but can also be linked with such information from other sources.

Notes on legal bases:* If we ask users for their consent to use third-party services, the legal basis for data processing is the permission. 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 regarding the use of cookies in this privacy policy.
Types of processed data: Usage data (e.g., page views and duration of visit, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Affected persons: Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest-/behavior-based profiling, use of cookies); audience formation. Marketing.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion." Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods can be stored on users' devices for a period of two years.).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Right to object (Opt-Out): Opt-Out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, settings for displaying ads: https://myadcenter.google.com/personalizationoff.

Management, organization, and support tools

We use services, platforms, and software from other providers (hereinafter referred to as "third parties") for the purposes of organization, administration, planning, and providing our services. When selecting third parties and their services, we adhere to legal requirements.

In this context, personal data may be processed and stored on the servers of third parties. Various data may be affected, which we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on transactions, contracts, other processes, and their contents.

If users are referred to third parties or their software or platforms in the context of communication, business, or other relationships with us, the third parties may process usage data and metadata for security purposes, service optimization, or marketing purposes. We therefore ask you to pay attention to the privacy notices of the respective third parties.

Types of processed data: Content data (e.g., textual or visual messages and posts as well as related information, such as authorship or creation time); usage data (e.g., page views and duration of visit, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Affected persons: Communication partners. Users (e.g., website visitors, users of online services).
Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion."
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures, and services:*
Confluence: Software for creating and administering wiki & knowledge platforms; Service provider: Atlassian Pty Ltd, 350 Bush Street, Floor 13, San Francisco, CA 94104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.atlassian.com/software/confluence; Privacy policy: https://www.atlassian.com/legal/privacy-policy. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.atlassian.com/legal/data-processing-addendum#europe-uk-switzerland).
Jira: Web application for bug tracking, issue handling, and operational project management; Service provider: Atlassian Pty Ltd, 350 Bush Street, Floor 13, San Francisco, CA 94104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.atlassian.com/software/jira; Privacy policy: https://www.atlassian.com/legal/privacy-policy; Data processing agreement: https://www.atlassian.com/legal/data-processing-addendum. Basis for third country transfers: Data Privacy Framework (DPF), standard contractual clauses (https://www.atlassian.com/legal/data-processing-addendum#europe-uk-switzerland).

Processing of data in the context of employment relationships

In the context of employment relationships, the processing of personal data aims to effectively establish, execute, and terminate such relationships. This data processing supports various operational and administrative functions necessary for managing employee relations.

This data processing encompasses various aspects, ranging from contract initiation to contract termination. Included are the organization and management of daily working hours, management of access rights and permissions, as well as handling personnel development measures and employee discussions. The processing also serves billing and management of salary payments, which are critical aspects of contract execution.

Additionally, the data processing considers the legitimate interests of the responsible employer, such as ensuring workplace safety or collecting performance data for evaluating and optimizing operational processes. Furthermore, the data processing includes the disclosure of employee data in the context of external communication and publication processes, where this is necessary for operational or legal purposes.

The processing of this data is always carried out in compliance with applicable legal frameworks, with the goal of creating and maintaining a fair and efficient working environment. This also includes consideration of the data protection of the affected employees, anonymization or deletion of data after the processing purpose has been fulfilled or according to legal retention periods.

Types of processed data: Employee data (information about employees and other persons in an employment relationship); payment data (e.g., bank details, invoices, payment history); contract data (e.g., subject matter of the contract, duration, customer category); inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts as well as related information, such as authorship or creation time); social data (data subject to social confidentiality and processed by social security agencies, social assistance agencies, or pension authorities.); log data (e.g., log files regarding logins or data retrieval or access times.); performance and behavior data (e.g., performance and behavior aspects such as performance evaluations, feedback from supervisors, training participation, compliance with company policies, self-assessments, and behavioral assessments.); working time data (e.g., start of working time, end of working time, actual working time, target working time, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g., base salary, bonus payments, premiums, tax class information, allowances for night work/overtime, tax deductions, social security contributions, net payment amount); image and/or video recordings (e.g., photographs or video recordings of a person); usage data (e.g., page views and duration of visit, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
Special categories of personal data: Health data; religious or philosophical beliefs. Union membership.
Affected persons: Employees (e.g., staff, applicants, temporary workers, and other employees).
Purposes of processing and legitimate interests: Establishment and execution of employment relationships (processing of employee data in the context of establishing and executing employment relationships); business processes and economic procedures; provision of contractual services and fulfillment of contractual obligations; public relations; security measures. Office and organizational procedures.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data related to healthcare, profession, and social security (Art. 9 para. 2 lit. h) GDPR).
Further information on processing processes, procedures, and services:*
Time tracking: Methods for recording employee working hours include both manual and automated methods, such as the use of time clocks, time tracking software, or mobile apps. Activities include entering clock-in and clock-out times, break times, overtime, and absences. Verification and validation of recorded working hours involve matching with deployment or shift schedules, checking for absences, and approving overtime by supervisors. Reports and analyses are generated based on recorded working hours to provide time records, overtime reports, and absence statistics for management and HR; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Access management: Procedures necessary for defining, managing, and controlling access rights and user roles within a system or organization (e.g., creating permission profiles, role-based and access-based control, reviewing and approving access requests, regular review of access rights, tracking and auditing user activities, creating security policies and procedures); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Special categories of personal data: Special categories of personal data are processed in the context of employment or to fulfill legal obligations. The processed special categories of personal data include data regarding the health, union membership, or religious affiliation of employees. This data may be shared with health insurance providers or used to assess employees' work ability or for occupational health management or for tax office purposes; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Sources of processed data: Personal data is processed that was obtained during the application and/or employment of employees. Additionally, if legally required, personal data is collected from other sources. These may include tax authorities for tax-related information, the respective health insurance for information on incapacity to work, third parties such as employment agencies, or publicly accessible sources like professional social networks during application processes; Legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Purposes of data processing: The personal data of employees is primarily processed for the establishment, execution, and termination of the employment relationship. Furthermore, processing this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to meet regulatory and supervisory requirements, to optimize electronic data processing processes, and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed to assert legal claims and to defend against legal disputes; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Transmission of employee data: Employee data is only processed internally by those departments that need it to fulfill operational, contractual, and legal obligations.

Data may only be shared with external recipients if this is legally required or if the affected employees have given their consent. Possible scenarios for this may include inquiries from authorities or in the case of asset formation benefits. Furthermore, the responsible party may transmit personal data to other recipients as necessary to fulfill their contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance providers, pension insurance carriers, retirement plan providers, and other social security agencies c) Authorities, courts (e.g., tax authorities, labor courts, other supervisory authorities in fulfilling reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the case of wage and salary garnishments f) Other entities to which legally mandatory declarations must be made.

Additionally, data may be shared with third parties if necessary for communication with business partners, suppliers, or other service providers. Examples include information in the sender area of emails or letterheads as well as creating profiles on external platforms; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Transmission of employee data to third countries: The transmission of employee data to third countries, i.e., countries outside the European Union (EU) and the European Economic Area (EEA), occurs only if necessary for the fulfillment of the employment relationship, legally required, or if employees have given their consent. Employees will be separately informed about the details, as legally required; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Business trips and travel expense accounting: Procedures necessary for planning, conducting, and settling business trips (e.g., booking travel, organizing accommodations and transportation, managing travel expense advances, submitting and reviewing travel expense reports, controlling and recording incurred costs, adhering to travel policies, managing travel expenses); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Payroll and wage accounting: Procedures necessary for calculating, paying, and documenting wages, salaries, and other employee benefits (e.g., recording working hours, calculating deductions and bonuses, remitting taxes and social security contributions, creating payroll statements, maintaining wage accounts, reporting to tax authorities and social security agencies); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Deletion of employee data: Employee data will be deleted according to German law when it is no longer necessary for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations are observed:

General personnel files - General personnel files (such as employment contracts, work references, supplementary agreements) are retained for up to three years after the termination of the employment relationship (§ 195 BGB).

Tax-relevant documents - Tax-relevant documents in the personnel file are retained for six years (§ 147 AO, § 257 HGB).

Information on wages and working hours - Information on wages and working hours for (accident) insured persons with wage proof is retained for five years (§ 165 I 1, IV 2 SGB VII).

Payroll lists including lists for special payments - Payroll lists including lists for special payments, provided a booking receipt is available, are retained for ten years (§ 147 AO, § 257 HGB).
Wage lists for interim, final, and special payments - Wage lists for interim, final, and special payments are retained for six years (§ 147 AO, § 257 HGB).
Documents related to employee insurance - Documents related to employee insurance, provided booking receipts are available, are retained for ten years (§ 147 AO, § 257 HGB).
Contribution statements to social security agencies - Contribution statements to social security agencies are retained for ten years (§ 165 SGB VII).

Wage accounts - Wage accounts are retained for six years (§ 41 I 9 EStG).

Applicant data - Retained for a maximum of six months after rejection is communicated.
Working time records (for more than 8 hours on weekdays) - Retained for two years (§ 16 II Working Time Act (ArbZG)).
Application documents (after online job posting) - Retained for three to a maximum of six months after rejection is communicated (§ 26
Federal Data Protection Act (BDSG) n.F., § 15 IV General Equal Treatment Act (AGG)).
Sick leave certificates (AU) - Retained for up to five years (§ 6 I Compensation Act (AAG)).
Documents on company pension schemes - Retained for 30 years (§ 18a Act to Improve Company Pension Schemes (BetrAVG)).
Employee illness data - Retained for twelve months after the onset of illness, provided that the absences do not exceed six weeks in one year.
Documents related to maternity protection - Retained for two years (§ 27 para. 5 Maternity Protection Act (MuSchG)).
Legal bases:* Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data related to healthcare, profession, and social security (Art. 9 para. 2 lit. h) GDPR).

Deletion of employee data: Employee data will be deleted according to Austrian law when it is no longer necessary for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or the interests of the employer. The following retention and archiving obligations are observed:

Data regarding income tax and contribution obligations according to § 132 para 1 BAO - 7 years. Start of the period - From the end of the relevant calendar year for the data.
Limitation period for the obligation to pay social security contributions according to § 68 ASVG (determination limitation) - 3 or 5 years. Start of the period - Generally from the due date of the contributions, in case of failure to report from the day of reporting.
Retention periods in social security - 7 years according to UGB.
Entitlement to vacation according to § 4 para 5 UrlG - 2 years from the end of the vacation year in which the vacation was accrued. Deadline start - 2 years after the end of the vacation year in which the vacation was accrued.
Entitlement to vacation compensation according to § 1486 Z 5 ABGB - 3 years. Deadline start - From the time the final settlement claims become due, which is the last working day.
Records and reports on workplace accidents according to § 16 ASchG - at least 5 years. Deadline start - From the day of the workplace accident.
Record of the transfer of workers according to § 13 para 3 AÜG - 5 years. Deadline start - The day the last wage claim of the transferred worker becomes due.
Youth register according to § 26 para 2 KJBG - 2 years. Deadline start - when the register is newly created, two years after the last entry.
Claims for compensation due to discriminatory termination of employment according to §§ 15 para 1a and 29 para 1a GlBG as well as § 7k para 1 in conjunction with para 2 Z 3 BEinstG - 6 months. Deadline start - From the time the termination is received.
Claims for compensation from the employer or employee due to premature termination of employment according to § 34 AngG or § 1162d ABGB - 6 months. Deadline start - From the time the claims become due, usually from the day the termination declaration is received.
Entitlement to the issuance of a service certificate according to § 1478 ABGB - 30 years. Deadline start - Upon termination of the employment relationship.
Claims for compensation due to discriminatory rejection of an application according to §§ 15 para 1 and 29 para 1 GlbG as well as § 7k para 1 in conjunction with para 2 Z 1 BEinstG - 6 months. Deadline start - from the day the rejection is received or 7 months from the application submission.
Claims for compensation of any interview costs according to § 1486 Z 5 ABGB - 3 years. Deadline start - The day the costs were incurred.
Liability for severance claims and company pensions after business transfer according to § 6 para 2 AVRAG - 5 years. Deadline start - Time of the business transfer.
Claims for compensation due to discriminatory rejection of a promotion according to §§ 15 para 1 and 29 para 1 GlbG as well as § 7k para 1 in conjunction with para 2 Z 1 BEinstG - 6 months. Deadline start - from the day the promotion rejection is received.
Claims for compensation due to discriminatory disadvantage in salary, voluntary social benefits, training and further education measures, or other working conditions according to §§ 15 para 1 and 29 para 1 GlbG as well as § 7k para 1 in conjunction with para 2 Z 5 BEinstG - 3 years. Deadline start - The time when the right could first have been exercised and the objective possibility to sue exists.
Claims for compensation due to discriminatory harassment according to §§ 15 para 1 and 29 para 1 GlbG as well as § 7k para 1 in conjunction with para 2 Z 4 BEinstG - 1 year. Deadline start - From the time of knowledge of the discrimination.
Claims for compensation due to discriminatory rejection of an application according to §§ 15 para 1 and 29 para 1 GlbG as well as § 7k para 1 in conjunction with para 2 Z 1 BEinstG - 6 months. Deadline start - from the day the rejection is received or 7 months from the application submission.
Claims for compensation due to sexual harassment according to § 15 para 1 GlbG - 3 years. Deadline start - From the time of knowledge of the discrimination.
Claims for compensation of any interview costs according to § 1486 Z 5 ABGB - 3 years. Deadline start - The day the costs were incurred.
Claims of the employee for wages or reimbursement of expenses as well as those of the employer for advances granted according to § 1486 Z 5 ABGB - 3 years. Deadline start - from the due date of the respective claims.
Limitation period for prosecution due to underpayment according to § 31 para 1 VStG in conjunction with § 29 para 4 LSD-BG - 3 years. Deadline start - from the due date of the salary.
Claims for damages of the employer against the employee from employee liability in cases of slight negligence according to § 6 DHG - 6 months. Deadline start - from the day they can be asserted.
Claims for damages of the employer against the employee from employee liability in cases of gross negligence or intent as well as other claims for damages of the employer according to § 1489 ABGB - 3 years or 30 years. Deadline start - For short deadlines from the knowledge of damage and injurer, for long deadlines from the occurrence of damage.

Personnel file management: Processes required for the organization, updating, and management of employee data and documents (e.g., recording of personal data, storage of employment contracts, certificates, and confirmations, updating data in case of changes, compiling documents for employee discussions, archiving personnel files, compliance with data protection regulations); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR), Processing of special categories of personal data related to healthcare, profession, and social security (Art. 9 para. 2 lit. h) GDPR).
Personnel development, performance evaluation, and employee discussions: Processes required in the area of promoting and further developing employees as well as assessing their performance and in the context of employee discussions (e.g., needs analysis for further training, planning and conducting training measures, creating performance evaluations, conducting goal-setting and feedback discussions, career planning and talent management, succession planning); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR), Processing of special categories of personal data related to healthcare, profession, and social security (Art. 9 para. 2 lit. h) GDPR).
Obligation to provide data: The responsible party informs employees that providing their data is necessary. This is generally the case when the data is required for establishing and executing the employment relationship or its collection is legally mandated. Providing data may also be necessary when employees assert claims or claims are due to employees. The execution of these measures or fulfillment of services depends on the provision of this data (for example, providing data for receiving wages); Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).
Publication and disclosure of employee data: Employee data will only be published or disclosed to third parties if this is necessary for fulfilling work tasks in accordance with the employment contract. This applies, for example, when employees are named as contact persons in correspondence, on the website, or in public registers after consultation or agreed task descriptions, or if the task area includes representative functions. This may also be the case when a presentation or communication with the public occurs in the context of task fulfillment, such as image recordings for public relations. Otherwise, publication of employee data only occurs with their consent or based on legitimate interests of the employer, for example, in stage or group photographs during a public event; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 S. 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 S. 1 lit. f) GDPR).

Application process

The application process requires applicants to provide us with the necessary data for their assessment and selection. The required information is derived from the job description or, in the case of online forms, from the information provided there.

Generally, the required information includes personal details such as name, address, a contact option, and proof of qualifications necessary for a position. Upon request, we are happy to provide additional information on what details are needed.

If available, applicants are welcome to submit their applications via our online form, which is encrypted according to the latest technology. Alternatively, it is also possible to send applications to us via email. However, we would like to point out that emails are generally not encrypted during transmission over the internet. Although emails are usually encrypted during transport, this does not occur on the servers from which they are sent and received. Therefore, we cannot take responsibility for the security of the application during its transmission between the sender and our server.

For the purposes of applicant search, submission of applications, and selection of applicants, we may use applicant management or recruitment software and platforms and services from third parties, in compliance with legal requirements.

Applicants are welcome to contact us regarding the method of submitting their application or to send their application by post.

Processing of special categories of data:* If special categories of personal data (Art. 9 para. 1 GDPR, e.g., health data, such as disability status or ethnic origin) are requested or disclosed by applicants during the application process, their processing occurs so that the responsible party or the affected person can exercise their rights arising from labor law and social security law and fulfill their related obligations, in the case of protecting vital interests of applicants or other persons or for purposes of health care or occupational medicine, for assessing the employee's ability to work, for medical diagnostics, for care or treatment in the health or social sector, or for managing systems and services in the health or social sector.
Deletion of data:* The data provided by applicants may be further processed in the case of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. The data of applicants will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Deletion occurs, subject to a legitimate revocation by the applicants, no later than after a period of six months, so that we can answer any follow-up questions regarding the application and fulfill our documentation obligations under the provisions for equal treatment of applicants. Invoices for any travel expense reimbursements will be archived in accordance with tax law requirements.
Inclusion in an applicant pool:* Inclusion in an applicant pool, if offered, occurs based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no impact on the ongoing application process, and that they can revoke their consent at any time for the future.
Processed data types: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, as well as related information such as authorship details or creation time). Applicant data (e.g., personal information, postal and contact addresses, application documents, and the information contained therein, such as cover letters, resumes, certificates, and other information voluntarily provided by applicants regarding their person or qualifications for a specific position).
Affected persons: Applicants.
Purposes of processing and legitimate interests: Application process (establishment and any subsequent execution as well as possible later termination of the employment relationship).
Retention and deletion: Deletion according to the information in the section "General Information on Data Storage and Deletion."
Legal bases: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Changes and updates

We kindly ask you to regularly check the content of our privacy policy. We will adjust the privacy policy as soon as changes in our data processing make this necessary. We will inform you when changes require your participation (e.g., consent) or any 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 we ask you to verify the information before contacting them.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Where terms are legally defined, their legal definitions apply. The following explanations are primarily intended for understanding.

Employees: Employees are individuals who are in an employment relationship, whether as staff, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer's obligation to pay the employee a salary while the employee provides their work. The employment relationship encompasses various phases, including establishment, where the employment contract is signed, execution, where the employee performs their work, and termination, when the employment relationship ends, whether through resignation, termination agreement, or otherwise. Employee data includes all information related to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance evaluations.
Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unique identification and communication.
Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service that helps deliver content from an online offering, especially large media files like graphics or program scripts, faster and more securely using regionally distributed servers connected via the internet.
Content data: Content data includes information generated during the creation, editing, and publication of all types of content. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
Contact data: Contact data are essential information that enables communication with individuals or organizations. This includes phone numbers, postal addresses, and email addresses, as well as communication means like social media handles and instant messaging identifiers.
Conversion measurement: Conversion measurement (also referred to as "visit action evaluation") is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where marketing measures occur and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to recognize patterns, make predictions, and improve the efficiency and quality of our services. This involves collecting, cleaning, and structuring data, training and applying AI models, and continuously reviewing and optimizing results, and is conducted solely with user consent or based on legal permission.
Performance and behavior data: Performance and behavior data refer to information related to how individuals perform tasks or behave in a specific context, such as in educational, work, or social environments. This data can include metrics such as productivity, efficiency, work quality, attendance, and compliance with policies or procedures. Behavioral data may encompass interactions with colleagues, communication styles, decision-making processes, and reactions to various situations. These types of data are often used for performance evaluations, training and development measures, and decision-making within organizations.
Meta, communication, and procedural data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details such as file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, transaction logs, and audit logs used for tracking and verifying operations.
Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that shows how users utilize applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data may also include usage frequency, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Additionally, usage data plays a crucial role in identifying trends, preferences, and potential issues within digital offerings.
Personal data: "Personal data" refers to any information relating to an identified or identifiable natural person (hereinafter referred to as "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, identification number, location data, online identifier (e.g., cookie), or one or more specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information," or simply "profiles," includes any automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects related to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
Log data: Log data are information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data are often used to analyze system issues, monitor security, or generate performance reports.
Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate visitor flows of an online offering and can include the behavior or interests of visitors regarding specific information, such as website content. With the help of reach analysis, operators of online offerings can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor the content of the websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis to recognize returning visitors and obtain more accurate analyses of the use of an online offering.
Remarketing: "Remarketing" or "retargeting" refers to the practice of noting which products a user has shown interest in on a website for advertising purposes, in order to remind the user of these products on other websites, for example, through advertisements.
Location data: Location data is generated when a mobile device (or another device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical means and functions for determining location. Location data indicates the specific geographical position of the device on Earth. For example, location data can be used to display map functions or other location-dependent information.
Tracking: "Tracking" refers to the ability to trace user behavior across multiple online services. Typically, behavioral and interest information regarding the used online services is stored in cookies or on the servers of the tracking technology providers (known as profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
Controller: The term "Controller" refers to the natural or legal person, authority, institution, or other entity that decides alone or jointly with others on the purposes and means of processing personal data.
Processing: "Processing" refers to any operation or set of operations performed on personal data, whether automated or not. The term is broad and encompasses practically any handling of data, including collection, evaluation, storage, transmission, or deletion.
Contract data: Contract data are specific information related to the formalization of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes the identification of the contracting parties as well as the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the nature of the agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special conditions or clauses. They serve as the legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
Payment data: Payment data includes all information necessary to process payment transactions between buyers and sellers. This data is critical for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction data, verification numbers, and billing information. Payment data may also contain information about payment status, chargebacks, authorizations, and fees.
Audience targeting: Audience targeting (in English "Custom Audiences") refers to the process of defining target groups for advertising purposes, such as displaying ads. For example, based on a user's interest in certain products or topics online, it can be inferred that this user is interested in ads for similar products or the online shop where they viewed the products. "Lookalike Audiences" refers to when suitable content is shown to users whose profiles or interests presumably match those of the users for whom the profiles were created. For the purpose of creating Custom Audiences and Lookalike Audiences, cookies and web beacons are typically used.

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Privacy Policy

Your data is important to us!

Privacy Policy

Preamble

Table of Contents

Responsible Party

Contact Data Protection Officer

Overview of Processing Activities

Types of Processed Data

Special Categories of Data

Categories of Affected Persons

Purposes of Processing

Relevant Legal Bases

Security Measures

Transmission of Personal Data

International Data Transfers

General information on data storage and deletion

Rights of the data subjects

Provision of the online offer and web hosting

Use of cookies

Contact and inquiry management

Artificial Intelligence (AI)

Video conferences, online meetings, webinars, and screen sharing

Cloud services

Newsletter and electronic notifications

Online game and contest "TRICK OR LEAN"

Web analysis, monitoring, and optimization

Online marketing

Presences in social networks (Social Media)

Plug-ins and embedded functions as well as content

Management, organization, and support tools

Processing of data in the context of employment relationships

Application process

Changes and updates

Definitions