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Legal Notice

Privacy Policy

Preamble

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

The terms used are not gender-specific.

Last updated: November 23, 2025

Table of Contents

Controller

Sven Weigel
Kranichstraße 19
46282 Dorsten
Germany

Email address: sven.wgl@gmail.com

Overview of Processing

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

Types of Data Processed

  • Inventory data
  • Employee data
  • Contact data
  • Content data
  • Usage data
  • Meta, communication and process data
  • Protocol data

Categories of Data Subjects

  • Employees
  • Users
  • Third parties
  • Whistleblowers

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations
  • Security measures
  • Organizational and administrative procedures
  • Provision of our online offering and user-friendliness
  • Information technology infrastructure
  • Whistleblower protection

Relevant Legal Bases

Relevant legal bases under 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 may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

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

Transfer of Personal Data

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

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or the disclosure or transfer of data to other persons, entities or companies (which becomes apparent from the postal address of the respective provider or if the data transfer to third countries is expressly mentioned in the privacy policy), 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 was recognized as a secure legal framework through an adequacy decision by the EU Commission on July 10, 2023. Additionally, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary protection level, while the Standard Contractual Clauses serve as additional security. Should changes occur within the framework of the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains adequately protected even in the event of political or legal changes.

For individual service providers, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. More information about the DPF and a list of certified companies can be found 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, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

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 there are no further legal bases for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist when legal obligations or special interests require longer retention or archiving of the data.

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

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

If multiple retention periods or deletion deadlines are specified for data, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

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

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
  • 8 years - Accounting documents such as invoices and cost documents (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents, and cash register receipts (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as to further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately, or alternatively, in accordance with legal requirements, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

Provision of Online Offering and Web Hosting

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

  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Meta, communication and process data (e.g., IP addresses, time information, identification numbers, persons involved); Protocol data (e.g., log files concerning logins or data retrieval or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices such as computers, servers, etc.); Security measures.
  • Retention and deletion: Deletion in accordance with 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 operations, procedures and services:

  • Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and as a rule IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid server overload (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the utilization of the servers and their stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Registration, Login and User Account

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

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

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

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); Protocol data (e.g., log files concerning logins or data retrieval or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures; Provision of our online offering and user-friendliness.
  • Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion"; Deletion after termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Registration with pseudonyms: Users may use pseudonyms instead of real names as usernames; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to a legal permission, obligation, or consent of the users; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • No obligation to retain data: It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the contract period; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Privacy Information for Whistleblowers

In this section, you will find information about how we handle data from persons who provide information (whistleblowers), as well as affected and involved parties within our whistleblower procedure. Our goal is to provide a straightforward and secure opportunity to report possible misconduct by us, our employees, or service providers, particularly for actions that violate laws or our internal compliance policies and ethical standards.

Legal bases (Germany): Insofar as we process data to fulfill our legal obligations in accordance with the German Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG), the legal basis for processing is Article 6(1)(c) GDPR and in the case of special categories of personal data Article 9(2)(g) GDPR, § 22 BDSG, each in conjunction with § 10 HinSchG. This relates to the obligation to establish and operate an internal whistleblower reporting office, fulfill its statutory tasks, and, in the case of use of data collected in the reporting procedure, take further investigations or employment law measures against persons who have been convicted of a violation.

Insofar as we process data (particularly in cases of established misconduct) in the context of or in preparation for legal defense, this is done on the basis of our legitimate interests in lawful and ethical conduct pursuant to Article 6(1)(f) GDPR.

Insofar as you have given us consent to process personal data for specific purposes, the processing is carried out on that basis pursuant to Article 6(1)(a) GDPR and in the case of special categories of personal data pursuant to Article 9(2)(a) GDPR. Consent can be revoked at any time with effect for the future.

Types of Data Processed

Within the framework of receiving and processing reports as well as in the subsequent whistleblower procedure, we may collect various data. This includes in particular the data provided by a whistleblower, such as:

  • Name, contact details, and location of the person providing the report
  • Names and data of possible witnesses or persons affected by the report
  • Names and data of persons against whom the report is directed
  • Data about the alleged misconduct
  • Further relevant details, if communicated by the whistleblower

For the purposes of fact-checking and further proceedings, we also process the following personal data:

  • Unique identification of the report
  • Contact details of the reporting person, if provided
  • Personal data of persons named in the report, if provided
  • Personal data of persons indirectly affected by the report
  • Results of investigations and measures taken
  • Communication records related to the report

Special Categories of Personal Data

It may occur that we collect special types of personal data within our activities, particularly when communicated by a whistleblower. These include:

  • Health-related data of a person
  • Data on racial or ethnic origin of persons
  • Information about religious or philosophical beliefs of a person
  • Information about sexual orientation of a person

This data is only processed when it is necessary for the processing and assessment of the report and the protection of the whistleblower or other affected persons requires it.

Use of Our Online Forms

Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called "incognito mode" of your browser. Here's how to open an incognito window:

  • On a Windows PC: Open your browser and press Ctrl+Shift+N
  • On a Mac: Open your browser and press Command+Shift+N
  • On mobile devices: Switch to private mode via the tab menu

When accessing our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of your access. This includes the IP address of your device. This data is temporarily stored in a log file and automatically deleted after a maximum of 30 days.

The processing of the IP address serves technical and administrative purposes of establishing connection to our website. It ensures the security, stability, and functionality of the whistleblower form and is an important component of our measures to ensure the confidential and secure processing of reports.

Provision of Name

You have the option to submit reports anonymously. Unless prohibited by national legislation, we recommend providing your name and contact details. This enables us to follow up on the report more effectively and, if necessary, contact you directly.

If you provide your name and contact details, your identity will be treated strictly confidentially. Exceptions to this confidentiality only exist if we are legally obligated to disclose your identity. This may be necessary to protect our rights or the rights of our employees, customers, suppliers, or business partners in legal or official proceedings.

Provision of Data to Third Parties

Data related to submitted reports will only be passed on to third parties under certain circumstances. This occurs either:

  • If you have given us your express consent to do so, or
  • If there is a legal obligation to disclose the data

Possible third parties include public authorities, government, regulatory, or tax authorities if disclosure is necessary to fulfill a legal or regulatory obligation. In addition, within the framework of legal provisions, we may engage lawyers and other professional advisors. These are authorized to examine alleged misconduct and take necessary measures following an investigation, such as initiating disciplinary or court proceedings. Furthermore, carefully selected and monitored service providers may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations within the framework of data processing.

Data Retention and Deletion

Personal data is only processed for as long as necessary to fulfill the processing purposes described above. If this data is no longer necessary for the stated purposes, it will be deleted. In certain situations, however, the data may be retained longer to meet legal requirements, insofar as this is necessary and proportionate. In such cases, the data is restricted in its use and only used for the specific legal purposes.

Technical and Organizational Measures

We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes. Incoming reports are handled by authorized persons who have access to the respective reports and carry out the subsequent review of the facts. Our employees are specially trained in handling confidential information and are bound by confidentiality obligations.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Employee data (information about employees and other persons in an employment relationship); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., textual or pictorial messages and contributions as well as information concerning them, such as information on authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Employees (e.g., employees, applicants, temporary workers, and other personnel); Third parties; Whistleblowers.
  • Purposes of processing: Whistleblower protection.
  • Retention and deletion: Deletion in accordance with information in the section "General Information on Data Storage and Deletion".
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and Updates

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

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

Definitions

In this section, you will find an overview of the terminology used in this privacy policy. To the extent that the terminology is legally defined, the legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as workers, 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 remuneration to the employee while the employee provides their work performance. The employment relationship encompasses various phases, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether by notice, termination agreement, or otherwise. Employee data is all information relating to these persons 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 assessments.
  • 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 information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions, or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data