Privacy Policy

Data protection

Preamble

With the following data protection declaration 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 data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of 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.

As of August 30, 2023

Table of contents

• preamble
• Responsible person
• Overview of processing
• Relevant legal bases
• Safety measures
• Transfer of personal data
• International data transfers
• Deletion of data
• Rights of data subjects
• Use of cookies
• Business benefits
• Provision of online offerings and web hosting
• Blogs and publication media
• Contact and inquiry management
• Application process
• Newsletters and electronic notifications
• Advertising communication via email, post, fax or telephone
• Web analysis, monitoring and optimization
• Presences in social networks (social media)
• Plugins and embedded functions and content
• Changes and updates to the data protection declaration

Responsible person

Swissmountainclinic AG

Strada Cantonale 53

CH-6540 GR Castaneda

Persons authorized to represent:

Ulf Torsten Wiechel

E-mail address:

info@swissmountainclinic.com

Phone:

+41 91 820 40 40

Relevant legal bases

**Relevant legal bases according to the GDPR:**Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases apply in individual cases, we will inform you of these in the data protection declaration.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)- The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
• Fulfillment of the 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 to take steps prior to entering into a contract at the data subject's request.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR)- Processing is necessary to fulfill a legal obligation to which the controller is subject.
• Protection of vital interests (Art. 6 Para. 1 Sentence 1 Letter d) GDPR)- Processing is necessary to protect the vital interests of the data subject or another natural person.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)- Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh them.
• Application process as a pre-contractual or contractual relationship (Art. 6 Para. 1 Sentence 1 Letter b) GDPR)- Insofar as special categories of personal data within the meaning of Article 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, so that the person responsible or the person concerned can provide him or her with information from the In order to be able to exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing will take place in accordance with Article 9 Paragraph 2 Letter b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for health care or occupational medicine purposes, for assessing the employee's ability to work, for medical diagnostics, the care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 Paragraph 2 Letter h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing takes place on the basis of Article 9 Paragraph 2 Letter a. GDPR.
• Processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR).
• Consent to the processing of special categories of personal data (Art. 9 Para. 2 lit. a) GDPR).
• Processing of special categories of personal data to protect vital interests (Art. 9 Para. 2 lit. c) GDPR).

**Relevant legal bases according to the Swiss Data Protection Act:**If you are in Switzerland, we process your data on the basis of the Federal Data Protection Act (“Swiss Data Protection Act” for short). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss Data Protection Act does not provide (unlike the GDPR, for example) that a legal basis for the processing of personal data must be specified. We only process personal data if the processing is lawful, carried out in good faith and proportionate (Art. 6 Para. 1 and 2 of the Swiss Data Protection Act). Furthermore, we only obtain personal data for specific purposes that are recognizable to the person concerned and only process it in such a way that it is compatible with these purposes (Art. 6 Para. 3 of the Swiss Data Protection Act).

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

Overview of processing

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

Types of data processed

• Inventory data.
• Payment details.
• Location data.
• Contact details.
• Content data.
• Contract data.
• Usage Data.
• Meta, communication and procedural data.
• Applicant data.

Special Categories of Data

• Health data.
• Data about sex life or sexual orientation.
• Religious or ideological beliefs.

Categories of data subjects

• Customers.
• Interested persons.
• Communication partner.
• User.
• Applicant.
• Business and contractual partners.
• patients.

Purposes of processing

• Provision of contractual services and fulfillment of contractual obligations.
• Contact inquiries and communication.
• Safety measures.
• Direct marketing.
• Range measurement.
• Office and organizational procedures.
• Managing and responding to inquiries.
• Application process.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

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 the access, input, disclosure, ensuring availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS encryption (https): To protect your data transmitted via our online offering, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transfer of personal data

As part of our processing of personal data, the data may be transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The 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, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing in the context of using third-party services or disclosing or transferring data to other persons , positions or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Furthermore, data transfers only take place if the level of data protection is otherwise secured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 Paragraph 1 GDPR). We will also inform you about the basics of third-country transfers for the individual providers from the third country, with the adequacy decisions taking precedence as the basics. Information on third country transfers and existing adequacy decisions can be found in the EU Commission's information offering:https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.

EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies and further information about the DPF can be found on the US Department of Commerce websitehttps://www.dataprivacyframework.gov/(in English). As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the persons concerned is guaranteed (Article 16 Swiss Data Protection Act). If the Federal Council has not determined adequate protection (list:https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anwissen-staats.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or internal company data protection regulations previously recognized by the FDPIC or a competent data protection authority of another country.

According to Article 16 of the Swiss Data Protection Act, exceptions for the disclosure of data abroad can be permitted if certain conditions are met, including the consent of the data subject, execution of the contract, public interest, protection of life or physical integrity, data made public or data from a data subject register provided for by law. These announcements are always made in accordance with legal requirements.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent for processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is not necessary for the purpose). Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

As part of our data protection information, we can provide users with further information about the deletion and storage of data that specifically applies to the respective processing processes.

Rights of data subjects

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

• Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.
• **Right to withdraw consent:**You have the right to revoke your consent at any time.
• **Right of providing information:**You have the right to request confirmation as to whether the data in question is being processed and to receive information about this data as well as 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 that the data concerning you be completed or that incorrect data concerning you be corrected.
• **Right to deletion and restriction of processing:**In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, to request a restriction on the processing of the data.
• **Right to data portability:**You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
• **Complaint to 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, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your place of work or the place of the alleged violation If you believe that the processing of your personal data violates the GDPR.

Rights of the data subjects according to the Swiss Data Protection Act:

As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:

• **Right to information:**You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
• **Right to data release or transfer:**You have the right to request that the personal data you have provided to us be released in a common electronic format.
• **Right to rectification:**You have the right to request that incorrect personal data concerning you be corrected.
• **Right to objection, deletion and destruction:**You have the right to object to the processing of your data and to request that personal data concerning you be deleted or destroyed.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. E.g. to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or functions used in an online offer. Cookies can also be used for various purposes, such as the functionality, security and convenience of online offerings and the creation of analyzes of visitor flows.

**Notes on consent:**We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that affect the display and functionality of the online offering, load balancing, security, serve to store the preferences and selection options of the users or similar purposes related to the provision of the main and secondary functions of the online offering requested by the users. The revocable consent is clearly communicated to the users and contains information on the respective cookie use.

Measurement without cookies: Google Analytics is loaded on every visit, but until you consent it runs with all storage denied: no cookie and no identifier is placed on your device, and you cannot be recognised on a later visit. Accepting in the cookie banner enables that storage, which is what allows a returning visit to be counted as one.

**Information on data protection legal bases:**The data protection legal basis on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is within the scope of fulfilling our contractual obligations, if the use of cookies is necessary for our purposes to fulfill contractual obligations. For what purposes we process cookies,

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

• **Temporary cookies (also: session or session cookies):**Temporary cookies are deleted at the latest after a user has left an online offer 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 or preferred content can be displayed directly when the user visits a website again. User data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

**General information on revocation and objection (so-called “opt-out”):**Users can revoke the consent they have given at any time and object to the processing in accordance with legal requirements. To do this, users can, among other things, restrict the use of cookies in their browser settings (which may also limit the functionality of our online offering). You can also object to the use of cookies for online marketing purposes via the websiteshttps://optout.aboutads.infoandhttps://www.youronlinechoices.com/be explained.

• **Legal basis:**Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Further information on processing processes, procedures and services:

• **Processing of cookie data based on consent:**We use a cookie consent management process, within which the users' consent to the use of cookies, or the processing and providers mentioned as part of the cookie consent management process, is obtained, managed and revoked by the users can be. The declaration of consent is saved so that it does not have to be asked again and to be able to prove consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information regarding the providers of cookie management services, the following information applies: The duration of storage of consent can be up to two years. Here, a pseudonymous user identifier is created and stored with the time of consent, information about the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Business benefits

We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as associated measures and as part of communication with the contractual partners (or pre-contractual), e.g. to respond to inquiries answer.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse and jeopardy of their data, secrets, information and rights (e.g. for the participation of telecommunications, Transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, through special marking (e.g. colors) or symbols (e.g. asterisks, etc.), or in person.

We delete the data after statutory warranty and comparable obligations have expired, ie, in principle after 4 years, unless the data is stored in a customer account, for example as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for commercial and business letters received and copies of the commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance,

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

• Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g. email, telephone numbers). Contract data (e.g. subject matter of the contract, term, customer category).
• Special categories of personal data: health data; Data about sex life or sexual orientation. Religious or ideological beliefs.
• Affected people: Interested persons; business and contractual partners; patients. Customers.
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact inquiries and communication; Office and organizational procedures. Managing and responding to inquiries.
• Legal basis: Fulfillment of the contract 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); Protection of vital interests (Art. 6 Para. 1 Sentence 1 Letter d) GDPR); Processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR); Consent to the processing of special categories of personal data (Art. 9 Para. 2 lit. a) GDPR); Processing of special categories of personal data to protect vital interests (Art. 9 Para. 2 lit. c) GDPR). Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Further information on processing processes, procedures and services:

• Pharmacy services and pharmaceutical services: We process the data of our customers and interested parties (uniformly referred to as "customers") in order to be able to provide them with our consulting and sales services. The data processed, the type, scope, purpose and necessity of their processing are determined according to the underlying contract and customer relationship and will be communicated to the customer in a timely manner.

• As part of our activities, we may also collect special categories of data, in particular information on the health of customers, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs emerge, process. To do this, if necessary, we obtain express consent from customers and otherwise process the special categories of data for health care purposes or to protect the customers' vital interests.

• When ordering prescription medicines, customers agree to the health data provided being passed on to their health insurance company if this is necessary for billing with the health insurance company.

• If it is necessary for the fulfillment of our contract, to protect vital interests or by law, to fulfill our obligation to provide pharmaceutical advice, or if the customer has given their consent, we disclose or transmit the customer's data to third parties or agents in compliance with professional regulations, such as authorities, medical facilities, laboratories, billing offices as well as in the area of ​​IT, office or comparable services;

• Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR), 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), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR), consent to the processing of special categories of personal data (Art. 9 Para. 2 lit. a) GDPR), processing of special Categories of personal data to protect vital interests (Art. 9 Para. 2 lit. c) GDPR).

• Medical and healthcare services: We process our patients' data in order to be able to provide them with our treatment services and bill them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and patient relationship and are communicated to the patients in a timely manner.

• As part of our work, we may also collect special categories of data, in particular information on the health of patients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or union affiliation. To do this, if necessary, we obtain express consent from patients and otherwise process the special categories of data for health care purposes or to protect the patients' vital interests.

• If it is necessary for the fulfillment of our contract, to protect vital interests or by law (e.g. to fulfill social law obligations and reporting obligations), or if the patient has given their consent, we disclose or transmit the patient's data to third parties or agents in compliance with professional regulations , such as authorities, medical facilities, laboratories, billing offices as well as in the area of ​​IT, office or comparable services.

• Your data will be retained for as long as is necessary to provide our services and any follow-up support. The retention period is usually ten years, but may vary in special cases due to special regulations, such as the requirements of the Radiation Protection Act;

• Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), protection of vital interests (Art. 6 Para. 1 S. 1 lit. d) GDPR), processing of special categories of personal data in relation to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR), consent to the processing of special categories of personal data (Art. 9 Paragraph 2 lit. a) GDPR), processing of special categories of personal data to protect vital interests (Article 9 para. 2 lit. c) GDPR).

• Therapeutic services: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined according to the underlying contract and client relationship.

• As part of our work, we may also collect special categories of data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or union affiliation. To do this, if necessary, we obtain express consent from the clients and otherwise process the special categories of data if this serves the health of the clients, the data is public or other legal permissions exist.

• If it is necessary for the fulfillment of our contract, to protect vital interests or by law, or if the client has given their consent, we disclose or transmit the client's data to third parties or agents, such as authorities, medical institutions, laboratories, in compliance with professional regulations. Billing offices as well as in the areas of IT, office or comparable services;

• Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Provision of online offerings and web hosting

We process users' data in order to be able 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. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status). Content data (e.g. entries in online forms).
• Affected people: 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 (computers, servers, etc.).). Safety measures.
• **Legal basis:**Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

• Provision of online offers on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a “web host”); Legal basis: Legitimate interests (Art. 6 Para. 1 S. 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 include the address and name of the websites and files accessed, date and time of access, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP address. Addresses and the requesting provider belong.
• The server log files can be used on the one hand for security purposes, for example to avoid overloading the servers (particularly 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 basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
• Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of emails (e.g. the providers involved) as well as the contents of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers' data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

• Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Affected people: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring person is processed to the extent that this is necessary to answer the contact request and any requested measures.

• Types of data processed: Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Affected people: Communication partner.
• Purposes of processing: Contact inquiries and communication; managing and responding to inquiries; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR). Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

• Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the request communicated; Legal basis: Fulfillment of the contract 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 that applicants provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

Basically, the required information includes personal information such as name, address, contact details and evidence of the qualifications required for a position. Upon request, we will also be happy to provide information about what information is required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, we ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management and/or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send us the 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 severely disabled status or ethnic origin) are requested from applicants as part of the application process, their processing is carried out by the person responsible or the person concerned exercise the rights conferred by labor law and social security and social protection law and fulfill his or her obligations in this regard, in the case of protecting the vital interests of applicants or other persons or for health or occupational medicine purposes, for the assessment of the person's ability to work employees, for medical diagnostics,for health or social care or treatment or for the management of health or social systems and services.

**Deletion of data:**If the application is successful, the data provided by the applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified revocation by the applicant, at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and fulfill our obligations to provide proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

**Inclusion in an applicant pool:**Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time in the future.

• **Types of data processed:**Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms). Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letters, CVs, certificates and other information about their person or qualifications provided voluntarily by applicants with regard to a specific position) .
• **Affected people:**Applicant.
• **Purposes of processing:**Application process (justification and possible subsequent implementation as well as possible later termination of the employment relationship).
• **Legal basis:**Application process as a pre-contractual or contractual relationship (Art. 6 Para. 1 Sentence 1 Letter b) GDPR); Processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 Para. 2 lit. h) GDPR); Consent to the processing of special categories of personal data (Art. 9 Para. 2 lit. a) GDPR). Processing of special categories of personal data to protect vital interests (Art. 9 Para. 2 lit. c) GDPR).

Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the content is specifically described as part of a registration for the newsletter, they are decisive for the consent of the user. Our newsletters also contain information about our services and us.

In order to register for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name so that you can be addressed personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

**Double opt-in procedure:**Registration for our newsletter generally takes place in a so-called double opt-in process. This means that after registering you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with someone else's email address. Registrations for the newsletter are logged in order to be able to provide evidence of the registration process in accordance with legal requirements. This includes storing the registration and confirmation times as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

**Deletion and restriction of processing:**We can store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the email address in a blacklist (so-called “blocklist”) solely for this purpose.

The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is based on our legitimate interests in an efficient and secure shipping system.

Contents:

Information about us, our services, promotions and offers.

• Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
• Affected people: Communication partner.
• Purposes of processing: Direct marketing (e.g. via email or post).
• Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).
• Option to object (opt-out): You can cancel your receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Further information on processing processes, procedures and services:

• Measuring open and click rates: The newsletters contain a so-called "web beacon", ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of access.

• This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

• The measurement of the opening rates and click rates as well as the storage of the measurement results in the users' profiles and their further processing are based on the users' consent.

• Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the saved profile information will be deleted;

• Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke their consent at any time or to object to the advertising communication at any time.

After revocation or objection, we store the data required to prove previous authorization to contact or send you up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of possible defense against claims. Based on the legitimate interest in permanently observing the user's revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

• Types of data processed: Inventory data (e.g. names, addresses). Contact details (e.g. email, telephone numbers).
• Affected people: Communication partner.
• Purposes of processing: Direct marketing (e.g. via email or post).
• Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR). Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Web analysis, monitoring and optimization

Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and can 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, identify at what time our online offering or its functions or content are used most frequently or invite reuse. We can also understand which areas require optimization.

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

Unless otherwise stated below, profiles, i.e. data summarized into a usage process, can be created for these purposes and information can be stored in a browser or in a device and read out from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information about times of use. If users have agreed to the collection of their location data to us or to the providers of the services we use, location data can also be processed.

The users’ IP addresses are also stored. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Affected people: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.
• Safety measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR). Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

• Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed within one or different usage processes, which search terms they have used, which they have accessed again or which have interacted with our online offering. The time of use and its duration are also stored, as are the sources of the users who refer 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, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the city's derived latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). For EU data traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible and are not used for any other purposes. When Google Analytics collects metrics, all IP queries are performed on EU-based servers before passing traffic to Analytics servers for processing; 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); Website:https://marketingplatform.google.com/intl/de/about/analytics/; Data protection:https://policies.google.com/privacy; Order processing contract:https://business.safety.google/adsprocessorterms/; Basis for third country transfer: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms); Option to object (opt-out): Opt-out plugin:https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements:https://adssettings.google.com/authenticated. Additional Information:https://privacy.google.com/businesses/adsservices(Types of processing and data processed).
• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) is therefore used, for example: For example, user profiles have not yet been created or cookies have been stored. Google only learns the user's IP address, which is necessary to run Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Website:https://marketingplatform.google.com; Data protection:https://policies.google.com/privacy; Order processing contract:
• https://business.safety.google/adsprocessorterms. Basis for third country transfer: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms).

Presences in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example, it could make it more difficult to enforce users' rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

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

• Types of data processed: Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Affected people: Users (e.g. website visitors, users of online services).
• Purposes of processing: Contact inquiries and communication; Feedback (e.g. collecting feedback via online form). Marketing.
• Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

• Instagram: Social network; Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:https://www.instagram.com. Data protection:https://instagram.com/about/legal/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); Data protection:https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out):https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

We include functional and content elements in our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter referred to as “content” ).

The integration always requires that the third party providers of this content process the users' IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website.

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms). Location data (information about the geographical position of a device or person).
• Affected people: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offering and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

• Google Fonts (provided on own server): Provision of font files for the purpose of a user-friendly presentation of our online offering; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
• Google Maps: We integrate the maps from the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website:https://mapsplatform.google.com/; Data protection:https://policies.google.com/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
• YouTube videos: video content; 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); Website:https://www.youtube.com; Data protection:https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Option to object (opt-out): Opt-out plugin:https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements:https://adssettings.google.com/authenticated.

Changes and updates to the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information for companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.