Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen 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 the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e. the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information Required by Law” on this website.

How do we record your data?

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

Other data shall be 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.

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 to analyze your user patterns.

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 without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host: Hetzner Online GmbH · Industriestr. 25 · 91710 Gunzenhausen · Deutschland

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

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

Information about the responsible party (referred to as the “controller” in the GDPR) · The data processing controller on this website is: NOVUS GmbH · Rebenring 33 · 38106 Braunschweig · Deutschland · Phone: +49 152 57695941 · E-mail: info@novusbike.com

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.).

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. tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

Designation of a data protection officer as mandated by law

We have appointed a data protection officer for our company. René Renger · Rebenring 33 · 3338106 Braunschweig · Phone: +49 152 57695941 · E-mail: info@novusbike.com

Information on data transfer to the USA

Our website uses, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities.

Revocation of your consent to the processing of data

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

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 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT 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 DATA PROTECTION DECLARATION. 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 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT 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 SECT. 2 GDPR).

Right to log a complaint with the competent supervisory agency

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

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or 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.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also 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.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments. Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their 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 eradicated. 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 at the address provided in section “Information Required by Law.”

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 at the address provided in section “Information Required by Law.” 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; if the processing of your personal data was/is conducted in an unlawful manner; if we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements; or if you have raised an objection pursuant to Art. 21 Sect. 1 GDPR. 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.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in section “Information Required by Law” to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are 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. In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g. cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g. the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. Cookies which are required for electronic communications, for certain functions you want to use, or which are necessary for optimization of the website shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. If consent to the storage of cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); 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. In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

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 these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested. The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists. This shall be without prejudice to any mandatory legal provisions – in particular retention periods.

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 processing your request. We do not pass these data on without your consent. These data are processed on the basis of Art. 6 Sect. 1 lit. 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 are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained. The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses. Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising

Matomo (formerly called Piwik)

This website uses the open source web analysis service Matomo. Matomo uses technologies that make it possible to recognize the user across multiple pages with the aim of analyzing the user patterns (e.g. cookies or device fingerprinting). The information recorded by Matomo about the use of this website will be stored on our server. Prior to archiving, the IP address will first be anonymized. Through Matomo, we are able to collect and analyze data on the use of our website by website visitors. This enables us to find out, for instance, when which page views occurred and from which region they came. In addition, we collect various log files (e.g. IP address, referrer, browser and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user patterns, in order to optimize the operator’s web offerings and advertising. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Hosting

We host Matomo exclusively on our own servers so that all analysis data remains with us and is not passed on.

Disable and re-enable tracking on demand

6. Plug-ins and Tools

YouTube with expanded data protection integration

Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition. Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 Sect. 1 lit. f GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time. For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

Google Web Fonts (local embedding)

This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application. For more information on Google Web Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

Font Awesome (local embedding)

This website uses Font Awesome to ensure the uniform use of fonts on this site. Font Awesome is locally installed so that a connection to Fonticons, Inc.’s servers will not be established in conjunction with this application. For more information on Font Awesome, please and consult the Data Privacy Declaration for Font Awesome under: https://fontawesome.com/privacy.

7. eCommerce and payment service providers

Processing of data (customer and contract data)

We collect, process and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them. The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.

Data transfer upon closing of contracts for online stores, retailers and the shipment of merchandise

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with companies entrusted with the shipment of goods or the financial institution tasked with the processing of payments. Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur. The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

8. Custom Services

Job Applications

We offer website visitors the opportunity to submit job applications to us (e.g. via e-mail, via postal services on 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.

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 they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 New GDPR according to German Law (Negotiation of an Employment Relationship), Art. 6 Sect. 1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6 Sect. 1 lit. 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 New GDPR and Art. 6 Sect. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing system.

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 para. 1 lit. 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 agreement (Article 6 (1) (a) GDPR) or if statutory data retention requirements preclude the deletion.

9. Social Media and Meta Technologies

We maintain profiles on social networks and may use advertising and measurement technologies supplied by Meta Platforms. The following information describes the intended processing. These services must remain disabled until you have given consent through the website’s consent-management system, unless a legally permissible consent-free configuration has been verified.

Facebook and Instagram profiles. When you visit or interact with our profiles, Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland, may process identifiers, device and usage data, interactions, messages, profile information, and similar information. If you contact us through a platform, we process the information required to answer your request. For audience statistics made available to page operators, NOVUS GmbH and Meta may act as joint controllers to the extent provided by applicable law and Meta’s Page Insights arrangements. Meta is primarily responsible for providing information about its platform processing and for enabling the exercise of data-subject rights regarding data held by Meta.

Meta Pixel and related event technologies. Subject to your prior consent, we may use Meta Pixel and, where implemented, Meta’s Conversions API to measure the effectiveness of advertisements, understand whether visitors perform defined actions, create aggregated reports, limit repeated advertising, and build or exclude audiences. Depending on implementation and consent, data may include page URLs, referrer information, browser and device information, IP address, timestamps, cookie and advertising identifiers, consent status, and events such as page views, configuration steps, contact requests, reservations, or purchases. Where advanced matching is enabled, contact data may be transformed before transmission. We will not intentionally transmit sensitive personal data.

Legal basis and consent. Storage of or access to information on your device and the subsequent processing of personal data for Meta advertising technologies are intended to occur only with your consent under Section 25(1) TDDDG and Article 6(1)(a) GDPR. You may refuse or withdraw consent at any time through the consent settings. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Refusing consent does not prevent use of the essential website functions.

Recipients and international transfers. Data may be received by Meta Platforms Ireland Limited, affiliated Meta companies, processors, and service providers. Processing may also take place in the United States and other countries outside the European Economic Area. Meta states that transfers are supported, where applicable, by adequacy decisions including the EU–US Data Privacy Framework and/or appropriate safeguards such as the European Commission’s Standard Contractual Clauses. The practical scope of processing is determined by Meta and by the configuration active when consent is given.

Retention. We retain campaign and measurement information only for as long as necessary for the stated purposes, to document consent, and to comply with statutory retention obligations. Cookie lifetimes, event retention, audience membership, and deletion periods must be configured in the consent platform, Meta Business tools, and any connected systems. Meta’s independent retention periods are governed by Meta’s own policies.

Your rights and further information. You may exercise the rights described in this Privacy Policy and may contact NOVUS GmbH using the details above. For processing performed independently by Meta, requests can also be directed to Meta. Further information is available in Meta’s Privacy Policy, Cookie Policy, information on Page Insights, and advertising settings. The final reviewed version must include working links to those documents and accurately identify every event, audience, matching feature, retention period, consent category, and transfer mechanism actually in use.

10. Analytics, Payments and Service Providers

Google Analytics 4. Subject to your prior consent, we intend to use Google Analytics 4, a web analytics service provided in the European Economic Area by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics may process page views, interactions, approximate location, technical browser and device information, referrer information, timestamps, consent signals, online identifiers, and an IP address that Google states is not logged or stored in full. The service helps us understand use of the website, measure campaigns, improve content and identify technical problems. Processing is based on your consent under Section 25(1) TDDDG and Article 6(1)(a) GDPR. Analytics must remain disabled until consent is granted and can be disabled again through the consent settings. The final configuration must document the actual measurement ID, enabled events, Google Signals status, advertising features, data-sharing settings, user-data collection, and the selected event and user-data retention periods.

Google Tag Manager and Consent Mode. We may use Google Tag Manager to manage website tags and Google Consent Mode to communicate consent choices to Google services. Google Tag Manager itself is intended to control scripts rather than create independent user profiles; however, technical connection data may be transmitted to Google when the service is loaded. Tags requiring consent must not fire before the relevant consent has been given. If advanced Consent Mode or cookieless measurement signals are enabled, this must be described and legally assessed before publication. Data may be processed by Google group companies and service providers in the United States and other countries. Google states that it relies, where applicable, on the EU–US Data Privacy Framework and/or Standard Contractual Clauses for relevant transfers.

Stripe. We use Stripe to process payments and, where applicable, prevent fraud, manage payment status, issue refunds, and meet legal and regulatory obligations. Depending on the payment method and transaction, Stripe may process name, billing and contact information, payment amount and currency, transaction data, bank or card-related information, device and browser data, IP address, risk indicators, and authentication information. Payment credentials are generally entered directly into Stripe-controlled interfaces and are not intended to be stored by NOVUS in full. The processing required to initiate and perform a payment is based on Article 6(1)(b) GDPR; fraud prevention, IT security, and legal compliance may additionally rely on Article 6(1)(c) or (f) GDPR. The relevant Stripe contracting entity, payment methods, fraud tools, retention periods, and international-transfer mechanism must be confirmed for the final sales setup. Stripe’s own privacy information applies to processing for which Stripe determines the purposes and means independently.

Calendly. We use Calendly to provide appointment booking. When you open or use an embedded scheduling interface, Calendly may process technical connection and usage data. When you book an appointment, the information you enter—such as name, email address, company, telephone number, time zone, selected appointment, answers to booking questions, and message content—is processed to arrange and conduct the appointment. Processing is based on Article 6(1)(b) GDPR where the appointment concerns contractual or pre-contractual communication and otherwise on Article 6(1)(f) GDPR in our legitimate interest in efficient scheduling. If the embedded service sets non-essential cookies or performs analytics, it must load only after consent under Section 25(1) TDDDG and Article 6(1)(a) GDPR. Calendly and its service providers may process data in the United States; the account region, integrations, retention settings, and transfer safeguards must be verified before publication.

n8n workflow automation. We use n8n to automate selected business processes and to transfer information between systems used for inquiries, reservations, appointments, applications, payments, support, and internal notifications. The categories of data processed depend on the individual workflow and may include contact, communication, customer, contract, appointment, application, transaction, and technical metadata. Processing follows the legal basis applicable to the underlying process, commonly Article 6(1)(b), (c), or (f) GDPR and, where consent is required, Article 6(1)(a) GDPR. Workflows must be configured according to data-minimization principles and protected by access controls. Before publication, the responsible team must document whether n8n is self-hosted or provided as a cloud service, the hosting location, subprocessors, credentials and logging behavior, execution-data retention, deletion rules, and each connected recipient.

JOIN recruitment platform. We use JOIN to publish vacancies and manage applications. If you open an embedded JOIN element or submit an application through JOIN, the platform may process technical connection data as well as the application information you provide, including contact details, curriculum vitae, qualifications, employment history, availability, salary expectations, links, attachments, communications, and interview notes. Processing for deciding on an employment relationship is based primarily on Section 26 BDSG and, where applicable, Article 6(1)(b) GDPR; consent may apply to voluntary talent-pool retention or optional information. Access is limited to persons involved in recruitment. Unsuccessful applications are deleted after the legally appropriate defense and retention period unless continued storage is required or separately consented to. The final policy must confirm whether JOIN is embedded or linked, the responsible JOIN entity, subprocessors, hosting locations, retention settings, talent-pool configuration, and any transfer outside the EEA.

Framer website platform. This website is created and delivered using Framer. Framer and its infrastructure or content-delivery providers may process technical connection and server-log data required to deliver and secure the website, including IP address, requested URL and assets, referrer, browser and device information, timestamps, error and diagnostic data, and security signals. This processing serves secure, reliable, and efficient website delivery and is based on Article 6(1)(f) GDPR. Where Framer-hosted forms, analytics, localization, fonts, videos, or other optional features are enabled, their additional processing must be separately assessed and described. Framer’s infrastructure may involve recipients or processing outside the EEA; the contracting entity, current subprocessors, hosting and CDN regions, log retention, transfer safeguards, and enabled project features must be verified. The existing reference to Hetzner covers separately hosted systems only and must not be presented as the sole website host if production traffic is delivered through Framer.

Consent management. We use a consent-management mechanism to request, store, and document choices regarding non-essential technologies. It may process consent status, consent time, policy version, a consent identifier, browser and device information, and technical connection data. This processing is necessary to meet our legal accountability obligations under Article 6(1)(c) GDPR and Section 25 TDDDG. The final text must identify the actual provider, cookie or local-storage names, retention period, and a permanently accessible method for changing or withdrawing consent.

Server, security, and diagnostic logs. Website and connected-system providers may automatically record IP address, access time, requested resource, response status, transferred data volume, referrer, browser, operating system, device information, and security events. Logs are used to deliver services, investigate errors, prevent abuse, and maintain system security on the basis of Article 6(1)(f) GDPR. Logs should be deleted or anonymized after the shortest operationally necessary period unless a security incident or statutory obligation requires longer storage. Retention periods for Framer, Hetzner, n8n, and other connected systems must be documented separately.

Google reCAPTCHA or comparable anti-abuse protection. If enabled on a form, such a service may analyze technical and interaction data to distinguish legitimate users from automated abuse. Because this may involve storage, device access, profiling, and transmission to a third party, it must not be described as active or loaded before the legal basis and consent requirements have been verified. If no such service is implemented, this paragraph must be removed from the final policy.