Privacy policy

Controller

Authorized representative: Christian Hollatz

Email address: kontakt@christian-hollatz.de

Phone: +49 171 7510707

Legal notice: christian-hollatz.de/en/imprint

Overview of processing operations

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

Types of data processed

• Master data.
• Payment data.
• Contact data.
• Content data.
• Contract data.
• Usage data.
• Meta, communication and process data.
• Log data.

Categories of data subjects

• Service recipients and clients.
• Prospective customers.
• Communication partners.
• Users.
• Business and contractual partners.

Purposes of processing

• Provision of contractual services and fulfillment of contractual obligations.
• Communication.
• Security measures.
• Office and organizational procedures.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online services and usability.
• Information technology infrastructure.
• Business processes and business management procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Should more specific legal bases be relevant in individual cases, we will inform you of these in this privacy policy.

• Performance of a contract and pre-contractual requests (Art. 6(1) sentence 1(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract.
• Legal obligation (Art. 6(1) sentence 1(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6(1) sentence 1(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. These include in particular the Act on the Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss FADP: This privacy notice serves to provide information both under the Swiss Federal Act on Data Protection (FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used because of their broader territorial application and comprehensibility. In particular, instead of the terms “processing” (Bearbeitung) of “personal data” (Personendaten), “overriding interest” and “sensitive personal data” used in the Swiss FADP, the terms used in the GDPR, “processing” of “personal data”, “legitimate interest” and “special categories of data”, are used. However, within the scope of the Swiss FADP, the legal meaning of these terms continues to be determined in accordance with the Swiss FADP.

Security measures

In accordance with the legal requirements, and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, input, disclosure, ensuring the availability and separation of the data. We have also established procedures to ensure that data subjects’ rights are exercised, that data is deleted and that we respond to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect users’ data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by HTTPS appearing in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transmission of personal data

In the course of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such cases, we comply with 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 transfer data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or if this happens in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be recognized by the postal address of the respective provider or where this privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and set out contractual obligations to protect your data.

This twofold safeguard ensures comprehensive protection of your data: the DPF forms the primary level of protection, while the standard contractual clauses serve as an additional safeguard. Should changes occur within the DPF framework, the standard contractual clauses take effect as a reliable fallback option. In this way, we ensure that your data always remains adequately protected, even in the event of political or legal changes.

For the individual service providers, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (opens in a new tab) (in English).

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en (opens in a new tab).

General information on data retention and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent has been withdrawn or there are no further legal bases for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist where statutory obligations or special interests require longer retention or archiving of the data.

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

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

Where there are several statements on the retention period or deletion periods for an item of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but on the basis of legal requirements or other reasons is processed by us exclusively for the reasons that justify its retention.

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

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the working instructions and other organizational documents required to understand them (Section 147(1) no. 1 in conjunction with (3) of the German Fiscal Code (AO), Section 14b(1) of the German VAT Act (UStG), Section 257(1) no. 1 in conjunction with (4) of the German Commercial Code (HGB)).
• 8 years – Accounting vouchers, such as invoices and expense receipts (Section 147(1) nos. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257(1) no. 4 in conjunction with (4) HGB).
• 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, and other documents insofar as they are relevant for taxation, e.g. hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting vouchers, and till receipts (Section 147(1) nos. 2, 3, 5 in conjunction with (3) AO, Section 257(1) nos. 2 and 3 in conjunction with (4) HGB).
• 3 years – Data required to take into account potential warranty and damage claims or similar contractual claims and rights, and to process related inquiries, based on previous business experience and customary industry practice, is stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 of the German Civil Code (BGB)).

Periods starting at the end of the year: If a period does not expressly begin on a specific date and is at least one year long, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the course of which data is stored, the event triggering the period is the date on which the termination or other ending of the legal relationship takes effect.

Rights of data subjects

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

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

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”), in the context of contractual and comparable legal relationships and related measures, and with regard to communication with contractual partners (or pre-contractually), for example to answer inquiries.

We use this data to fulfill our contractual obligations. These include in particular the obligations to provide the agreed services, any update obligations and remedies in the event of warranty claims and other performance issues. In addition, we use the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations, as well as for business organization. We also process the data on the basis of our legitimate interests both in proper and economically sound business management and in security measures to protect our contractual partners and our business operations from misuse and from threats to their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about other forms of processing, for example for marketing purposes, within the scope of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. for as long as it must be retained for legal archiving reasons (for tax purposes, usually ten years). Data disclosed to us by the contractual partner in the context of an order is deleted in accordance with the requirements and generally after the order has been completed.

Types of data processed

Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. subject matter of the contract, term, customer category).

Data subjects

Service recipients and clients; prospective customers. Business and contractual partners.

Purposes of processing

Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.

Retention and deletion

Deletion in accordance with the information in the section “General information on data retention and deletion”.

Legal bases

Performance of a contract and pre-contractual requests (Art. 6(1) sentence 1(b) GDPR); Legal obligation (Art. 6(1) sentence 1(c) GDPR). Legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Business processes and procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, legal clients, patients or business partners as well as other third parties – is processed in the context of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business operations in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfill contractual obligations and to make operational processes efficient. This includes processing business transactions, managing customer relationships, optimizing sales strategies and ensuring internal invoicing and financial processes. In addition, the data helps to safeguard the rights of the controller and supports administrative tasks and the organization of the business.

Personal data may be disclosed to third parties if this is necessary to fulfill the stated purposes or legal obligations.

Types of data processed

Master data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).

Data subjects

Service recipients and clients; prospective customers; communication partners. Business and contractual partners.

Purposes of processing

Provision of contractual services and fulfillment of contractual obligations; office and organizational procedures. Business processes and business management procedures.

Retention and deletion

Deletion in accordance with the information in the section “General information on data retention and deletion”.

Legal bases

Performance of a contract and pre-contractual requests (Art. 6(1) sentence 1(b) GDPR). Legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Provision of the online services and web hosting

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

Types of data processed

Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and features); meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved). Log data (e.g. log files relating to logins, data retrieval or access times).

Data subjects

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

Purposes of processing

Provision of our online services and usability; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.

Retention and deletion

Deletion in accordance with the information in the section “General information on data retention and deletion”.

Legal bases

Legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers, or for security reasons. For everything else, we refer to the information on the processing of visitors to our publication medium within this privacy notice.

Types of data processed

Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).

Data subjects

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

Purposes of processing

Feedback (e.g. collecting feedback via an online form). Provision of our online services and usability.

Retention and deletion

Deletion in accordance with the information in the section “General information on data retention and deletion”.

Legal bases

Legitimate interests (Art. 6(1) sentence 1(f) GDPR).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, phone or via social media), as well as in the context of existing user and business relationships, the information provided by the persons making the inquiry is processed to the extent necessary to respond to the contact inquiries and any requested measures.

Types of data processed

Master data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or phone numbers); content data (e.g. text or image messages and posts as well as information relating to them, such as details of authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, time stamps, identification numbers, persons involved).

Data subjects

Communication partners.

Purposes of processing

Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via an online form). Provision of our online services and usability.

Retention and deletion

Deletion in accordance with the information in the section “General information on data retention and deletion”.

Legal bases

Legitimate interests (Art. 6(1) sentence 1(f) GDPR). Performance of a contract and pre-contractual requests (Art. 6(1) sentence 1(b) GDPR).

Changes and updates

We ask you to check the content of our privacy policy regularly. We adapt the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or any other individual notification.

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time, and please check the information before contacting them.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

Master data

Master data comprises essential information required to identify and manage contractual partners, user accounts, profiles and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unambiguous assignment and communication.

Content data

Content data comprises information generated in the course of creating, editing and publishing content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information and publication dates.

Contact data

Contact data is essential information that enables communication with persons or organizations. It includes, among other things, phone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.

Meta, communication and process data

Meta, communication and process data are categories that contain information about the way in which data is processed, transmitted and managed. Metadata, also known as data about data, comprises information that describes the context, origin and structure of other data. It may include details of file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.

Usage data

Usage data refers to information that captures how users interact with digital products, services or platforms. This data covers a wide range of information showing how users use applications, which features they prefer, how long they stay on certain pages and which paths they take to navigate through an application. Usage data may also include frequency of use, time stamps of activities, IP addresses, device information and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings.

Personal data

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Log data

Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.

Controller

The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processing

“Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, analysis, storage, transmission or erasure.

Contract data

Contract data is specific information relating to the formalization of an agreement between two or more parties. It documents the terms under which services or products are provided, exchanged or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include the start and end dates of the contract, the type of services or products agreed, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. It serves as the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.

Payment data

Payment data comprises all information required to process payment transactions between buyers and sellers. This data is of crucial importance for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and invoice information. Payment data may also include information about payment status, chargebacks, authorizations and fees.