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Legal

Privacy Policy (Data Protection)

Last updated: 08/2026

§ 1  An overview of data protection

1. General information

The following information provides an easy-to-navigate overview of what happens with your personal data when you visit this website. The term "personal data" comprises all data that can be used to personally identify you. For detailed information about data protection, please consult the full privacy policy below.

This privacy policy applies to this website as well as to the administration of customer accounts and contractual relationships in connection with the XOAP platform (§ 5). Insofar as personal data is processed within the XOAP platform on behalf of our customers, this privacy policy does not apply; the relevant document is the data processing agreement concluded with the respective customer (§ 5 no. 3).

2. Data recording on this website

2.1 Who is the responsible party for the recording of data on this website (the "controller")?

The data on this website is processed by the operator of the website, whose contact information is available under the section "Information about the responsible party (referred to as the 'controller' in the GDPR)" in this privacy policy.

2.2 How do we record your data?

We collect your data as a result of your sharing it with us. This may, for instance, be information you enter into our contact form.

Other data is recorded by our IT systems automatically, or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

2.3 What are the purposes we use your data for?

A portion of the information is generated to guarantee the error-free provision of the website. Other data may be used, with your consent, to analyze your usage patterns.

2.4 What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time, free of charge. You also have the right to demand that your data be rectified or erased. If you have consented to data processing, you may revoke this consent at any time with effect for the future. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances, and you have the right to lodge a complaint with the competent supervisory authority.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issue.

3. Analysis tools and tools provided by third parties

When you visit this website, your browsing patterns may be statistically analyzed, primarily with what the industry refers to as analysis programs. Such analyses take place only with your consent. For detailed information about these analysis programs, please consult the sections below.

§ 2  Hosting

We host the content of our website with the following provider:

1. Amazon Web Services (AWS)

The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter referred to as "AWS").

When you visit our website, your personal data is processed on AWS servers. This may also result in the transfer of personal data to the parent company of AWS in the United States.

AWS is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, the transfer of data to the US is safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. For details, please consult: https://aws.amazon.com/blogs/security/aws-gdpr-data-processing-addendum/.

For more information, please see the AWS Data Privacy Policy: https://aws.amazon.com/privacy/.

AWS is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in a depiction of our website that is as reliable as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act), insofar as the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting). This consent can be revoked at any time.

1.1 Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that the provider processes personal data of our website visitors only based on our instructions and in compliance with the GDPR.

§ 3  General information and mandatory information

1. Data protection

The operators of this website take the protection of your personal data very seriously. We handle your personal data as confidential information and in compliance with the statutory data protection regulations and this privacy policy.

Whenever you use this website, a variety of personal information is collected. Personal data comprises data that can be used to personally identify you. This privacy policy explains which data we collect, as well as the purposes for which we use this data.

We herewith advise you that the transmission of data via the Internet (e.g., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

2. Information about the responsible party (referred to as the "controller" in the GDPR)

The data processing controller on this website is:

RIS AGWerderstraße 2150672 KölnGermany
Phone: +49 221 643083-0E-mail: info@ris.ag

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

3. Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons cease to apply.

4. General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed according to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25(1) TDDDG. This consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

5. Data protection officer

We have appointed a data protection officer:

Klaus PampuchPhone: +49 2204 7060940E-mail: pampuch@five.consulting

6. Information on data transfers to the USA and other third countries

Some of the tools and services we use are provided by companies domiciled in the United States or in other countries outside the EU/EEA in which the GDPR does not apply directly. If these tools are active, your personal data may be transferred to and processed in these third countries.

Wherever possible, we work with providers that are certified in accordance with the EU-U.S. Data Privacy Framework (DPF). The DPF is based on an adequacy decision of the European Commission pursuant to Art. 45 GDPR, under which companies certified in the United States are deemed to ensure a level of data protection essentially equivalent to that within the EU. A list of certified companies is available at: https://www.dataprivacyframework.gov/list.

In addition, or where a provider is not DPF-certified, transfers are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission pursuant to Art. 46(2)(c) GDPR, which contractually oblige the recipient to handle personal data in accordance with European data protection standards. Details on the safeguards applicable to each service can be found in the respective sections of this privacy policy.

Please note that, despite these safeguards, it cannot be entirely ruled out that authorities in third countries (e.g., security or intelligence agencies in the United States) access transferred data on the basis of local law. We have no control over such processing activities.

7. Revocation of your consent to the processing of data

A wide range of data processing operations are possible only subject to your express consent. You can revoke any consent you have already given us at any time. This shall be without prejudice to the lawfulness of any data processing that occurred prior to your revocation.

8. Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS PRIVACY POLICY. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING, PROTECTION-WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS, OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

9. Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects are entitled to lodge a complaint with a supervisory authority, in particular in the member state where they usually maintain their domicile or place of work, or at the place where the alleged violation occurred. The right to lodge a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

The supervisory authority responsible for us is: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany, https://www.ldi.nrw.de.

10. Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

11. Information about, rectification and erasure of data

Within the scope of the applicable statutory provisions, you have the right to demand, at any time, information about your archived personal data, its source and recipients, as well as the purpose of the processing of your data. You may also have a right to have your data rectified or erased. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

12. Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was or is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the erasure of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its erasure.
  • If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent, or to claim, exercise or defend legal entitlements, or to protect the rights of other natural persons or legal entities, or for important public interest reasons cited by the European Union or a member state of the EU.

13. SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as inquiries you submit to us as the website operator, this website uses SSL or TLS encryption. You can recognize an encrypted connection by checking whether the address line of the browser switches from "http://" to "https://" and by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

§ 4  Recording of data on this website

1. Cookies

Our website uses what the industry refers to as "cookies." Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites.

Cookies have a variety of functions. Many cookies are technically essential, since certain website functions would not work in their absence. Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies that are required for the performance of electronic communication transactions, for the provision of certain functions you want to use, or for the optimization of the website (required cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of its services. The storage of and access to information in your end device that is strictly necessary for providing this website occurs on the basis of § 25(2) TDDDG. If your consent to the storage of cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25(1) TDDDG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed, and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general, or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Which cookies and services are used on this website can be found in this privacy policy.

2. Consent with CCM19

Our website uses the consent management service CCM19 to obtain your consent for the storage of certain cookies on your device or for the use of specific technologies, and to document this consent in a data protection compliant manner. The provider of this technology is Papoo Software & Media GmbH, Auguststraße 4, 53229 Bonn, Germany (hereinafter referred to as "CCM19").

When you access our website, a connection with the servers of CCM19 is established to obtain your consent and other declarations related to the use of cookies. Subsequently, CCM19 stores a cookie in your browser to be able to allocate the granted consent or its revocation. The data generated in this manner is archived until you ask us to delete it, delete the CCM19 cookie yourself, or the purpose for the archiving of the data no longer applies. This shall be without prejudice to any mandatory statutory retention periods.

We use CCM19 to obtain the consent for the use of cookies mandated by law. The legal basis for this is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR and § 25(1) TDDDG.

2.1 Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that the provider processes personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. Server log files

The provider of this website automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of the browser used
  • The operating system used
  • The referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error-free depiction and optimization of the operator's website. To achieve this, server log files must be recorded.

4. Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form, as well as any contact information provided therein, will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of this data is based on Art. 6(1)(b) GDPR, if your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the requests addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested; consent can be revoked at any time.

The information you have entered into the contact form shall remain with us until you ask us to erase the data, revoke your consent to the archiving of data, or the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

5. Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request), will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data is processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR), if it has been obtained; consent can be revoked at any time.

The data you send to us via contact requests remains with us until you request its deletion, revoke your consent to its storage, or the purpose for the data storage lapses (e.g., after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

6. Microsoft Bookings

Our website gives you the option to schedule appointments with us. We use Microsoft Bookings to book these appointments. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, https://learn.microsoft.com/en-us/microsoft-365/bookings/.

To book an appointment, enter the requested data and the desired date in the form provided. The data entered will be used for planning, conducting and, if necessary, following up on the appointment. The appointment data is stored for us on the servers of Microsoft Bookings, whose privacy policy you can view here: https://privacy.microsoft.com/en-us/privacystatement.

The data recorded in this manner is stored until you ask us to delete it, revoke your consent to its archiving, or the purpose of archiving the data no longer exists. This does not affect mandatory statutory provisions – in particular those governing retention periods.

The legal basis for the processing of the data is Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in ensuring that appointments with customers and prospective customers can be scheduled as easily as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting). This consent can be revoked at any time.

Microsoft is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses of the EU Commission. Details can be found here: https://learn.microsoft.com/en-us/compliance/regulatory/offering-eu-model-clauses.

§ 5  Customer Accounts and the XOAP Platform

1. Account registration and administration

If you register for the XOAP platform (e.g., via auth.xoap.io), we process the data you provide during registration (e.g., name, business e-mail address, organization, user name) as well as account and login data in order to provide, secure and administer your user account. The legal basis is Art. 6(1)(b) GDPR (performance of a contract or implementation of pre-contractual measures).

2. Contract and billing data

For the conclusion, performance and billing of contracts concerning the XOAP platform, we process contract master data as well as order and billing data of our customers and their contact persons. The legal basis is Art. 6(1)(b) GDPR; insofar as we are subject to statutory retention obligations (e.g., under commercial and tax law), the processing is based on Art. 6(1)(c) GDPR. This data is deleted after the expiry of the statutory retention periods.

3. Processing within the platform on behalf of our customers

Insofar as personal data is processed within the XOAP platform in the course of its use by our customers (e.g., configuration, telemetry and log data of managed systems and their users), RIS processes this data as a processor on behalf of the respective customer pursuant to Art. 28 GDPR. This processing is not governed by this privacy policy but by the Data Processing Agreement (DPA) concluded with the customer, including its annexes (subject matter of the processing, technical and organizational measures, approved sub-processors), which forms part of the contractual documentation of RIS.

§ 6  Analysis tools and advertising

1. Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google's parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on its website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting). This consent can be revoked at any time.

Google is certified in accordance with the EU-U.S. Data Privacy Framework (DPF).

2. Google Analytics

This website uses functions of the web analysis service Google Analytics (Google Analytics 4). The provider of this service is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the operating system used and the user's origin. This data is assigned to the respective end device of the visitor via a user ID.

Furthermore, Google Analytics allows us to record, among other things, your mouse and scroll movements and clicks. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing user behavior patterns possible (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule, transferred to a Google server in the United States, where it is stored.

The use of this service occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Google is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

2.1 Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google's Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

2.2 Data processing agreement

We have executed a data processing agreement with Google and implement the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

3. Google Marketing Platform (formerly "DoubleClick")

This website uses features of the Google Marketing Platform (formerly "DoubleClick"). The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

This service is used to show you interest-based ads across the Google Network. Advertisements can be tailored to the interests of the viewer. For example, our ads may appear in Google search results or in banners associated with the Google Network.

To be able to display interest-adequate promotional content to users, the service must recognize the respective visitor so that it can allocate the websites visited, the clicks and other user pattern information to the user. To do this, the service deploys cookies or comparable recognition technologies (e.g., device fingerprinting). The recorded information is consolidated into a pseudonymous user profile so that the respective user can be shown interest-adequate advertising.

The use of this service occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.

Google is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission.

For further information on how to object to the advertisements displayed by Google, please see the following links: https://policies.google.com/technologies/ads and https://adssettings.google.com/authenticated.

4. LinkedIn Insight Tag

This website uses the Insight Tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

4.1 Data processing by LinkedIn Insight Tag

We use the LinkedIn Insight Tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use the LinkedIn Insight Tag to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g., from PC to tablet). The LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data is then deleted within 180 days.

The data collected by LinkedIn cannot be assigned by us as the website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy.

4.2 Legal basis

If your consent has been obtained, the use of the above-mentioned service occurs on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service occurs on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising promotions that include the utilization of social media.

LinkedIn is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

4.3 Objection to the use of the LinkedIn Insight Tag

You can object to LinkedIn's analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

In addition, LinkedIn members can control the use of their personal information for promotional purposes in their account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

§ 7  Newsletter

1. Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you, as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected, or is collected only on a voluntary basis. For the handling of the newsletter, we use the newsletter service provider described below.

2. Mailchimp

This website uses the services of Mailchimp to send out its newsletters. The provider is the Rocket Science Group LLC d/b/a Mailchimp, an Intuit company, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (hereinafter "Mailchimp").

Among other things, Mailchimp is a service that can be deployed to organize and analyze the sending of newsletters. Whenever you enter data for the purpose of subscribing to a newsletter (e.g., your e-mail address), the information is stored on Mailchimp servers in the United States.

With the assistance of the Mailchimp tool, we can analyze the performance of our newsletter campaigns. If you open an e-mail that has been sent through the Mailchimp tool, a file that has been integrated into the e-mail (a so-called web beacon) connects to Mailchimp's servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g., the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Its sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.

If you do not want to permit an analysis by Mailchimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider, and deleted from the newsletter distribution list after you unsubscribe. Data stored with us for other purposes remains unaffected.

Mailchimp (Intuit Inc.) is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/.

2.1 Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that the provider processes personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. E-mail marketing to existing customers

We use your e-mail address, which we obtained as part of an XOAP booking, to electronically send advertising for XOAP products and services similar to those you have booked, unless you have objected to this use (§ 7(3) of the German Act Against Unfair Competition – UWG). The processing is based on our legitimate interest in direct marketing (Art. 6(1)(f) GDPR). You can object to this use of your e-mail address at any time by notifying us, without incurring any costs other than the transmission costs according to the basic rates. You can also use the link provided in every marketing e-mail for this purpose.

§ 8  Custom services

1. Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services or by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions, and that your data will always be treated as strictly confidential.

1.1 Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if it is required to make a decision concerning the establishment of an employment relationship. The legal grounds for the aforementioned are § 26 BDSG (German Federal Data Protection Act – negotiation of an employment relationship), Art. 6(1)(b) GDPR (general contract negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

1.2 Data archiving period

If we are unable to make you a job offer, or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your consent (Art. 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

1.3 Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express consent (Art. 6(1)(a) GDPR). The consent is voluntary and has no relation to the ongoing application procedure. The affected person can revoke this consent at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

§ 9  Our social media presences

1. This privacy policy applies to the following social media presences

2. Data processing through social networks

We maintain publicly available profiles in social networks. The individual social networks we use can be found below.

Social networks can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g., like buttons or banner ads). When you visit our social media pages, numerous data protection relevant processing operations are triggered. In detail:

If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. This way, you can be shown interest-based advertising inside and outside of the respective social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.

Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policies of the respective social media portals.

3. Legal basis

Our social media presences are intended to ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g., consent within the meaning of Art. 6(1)(a) GDPR).

4. Responsibility and assertion of rights

If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle assert your rights (information, rectification, erasure, restriction of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal.

Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.

5. Storage time

The data collected directly from us via the social media presence will be deleted from our systems as soon as you ask us to delete it, you revoke your consent to the storage, or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular, retention periods – remain unaffected.

We have no control over the storage duration of your data that is stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g., in their privacy policy, see below).

6. Your rights

You have the right to receive information about the origin, recipients and purposes of your stored personal data at any time and free of charge. You also have the right to object, the right to data portability and the right to lodge a complaint with the competent supervisory authority. Furthermore, you can request the rectification, blocking, erasure and, under certain circumstances, the restriction of the processing of your personal data.

7. Individual social networks

7.1 Facebook

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter "Meta"). According to Meta's statement, the collected data will also be transferred to the USA and to other third-party countries.

We have signed an agreement with Meta on shared responsibility for the processing of data (Controller Addendum). This agreement determines which data processing operations we or Meta are responsible for when you visit our Facebook page. This agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

You can customize your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.

Meta is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum.

Details can be found in the Meta privacy policy: https://www.facebook.com/about/privacy/.

7.2 X (formerly Twitter)

We use the short message service X (formerly Twitter). The provider is X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

You can customize your X privacy settings in your user account. Click on the following link and log in: https://x.com/settings/privacy_and_safety.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.x.com/en/faq.html.

For details, see the X privacy policy: https://x.com/en/privacy.

7.3 LinkedIn

We have a LinkedIn profile. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

LinkedIn is certified in accordance with the EU-U.S. Data Privacy Framework (DPF). In addition, data transfers to the US are safeguarded by the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

For details on how they handle your personal information, please refer to LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy.

7.4 YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google is certified in accordance with the EU-U.S. Data Privacy Framework (DPF).

Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.

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