Privacy Policy

As of November 23, 2025

Table of Contents

Responsible

Yashvardhan Kothari
c/o Online-Impressum.de #4929
Europaring 90
53757 Sankt Augustin
Germany

Email address: the-morning-surge@mail.online-impressum.de

Legal notice: https://mein.online-impressum.de/the-morning-surge/

Overview of processing activities

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.

  • Employee data.

  • Contact details.

  • Content data.

  • Usage data.

  • Metadata, communication data and process data.

  • Log data.

Categories of affected persons

  • Employees

  • Communication partner.

  • Users.

  • Third parties.

  • Whistleblower.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.

  • Communication.

  • Security measures.

  • Direct marketing.

  • Range measurement.

  • Office and organizational procedures.

  • Conversion measurement.

  • Organizational and administrative procedures.

  • Server monitoring and error detection.

  • Feedback.

  • Provision of our online services and user-friendliness.

  • Information technology infrastructure.

  • Whistleblower protection.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under 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. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The 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 para. 1 sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (BDSG). The BDSG contains specific provisions regarding 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 data transfers, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Security measures

In accordance with legal requirements, 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 threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we rely on 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), thus protecting the data from unauthorized access. TLS, as the more advanced and 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 the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose this data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure its protection.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the data transfer 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 on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

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

For each service provider, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information about the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission's information service: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal regulations as soon as the underlying consents are withdrawn or no further legal basis for processing exists. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy policy contains additional information on the storage and deletion of data, which applies specifically to certain processing operations.

In cases where multiple retention periods or deletion deadlines for a given date are specified, the longest period always applies. Data that is no longer retained for its originally intended purpose, but is retained due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.

Data retention and deletion: The following general retention periods apply to data storage and archiving under German law:

  • 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).

  • 8 years - accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).

  • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating statements, costing documents, price labels, but also payroll documents, insofar as they are not already accounting documents and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).

  • 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Commencement of a time limit at the end of the year: If a time limit does not expressly begin on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the event triggering the time limit occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the time limit is the effective date of the termination or other end of the legal relationship.

Rights of data subjects

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

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.

  • Right to information: You have the right to request 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 legal requirements.

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.

  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.

  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.

  • 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 relating to you infringes the GDPR.

Provision of the online service and web hosting

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

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Log data (e.g., log files concerning logins or data retrieval or access times).

  • Affected persons: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures; reach measurement (e.g., access statistics, recognition of returning visitors); conversion measurement (measuring the effectiveness of marketing measures). Server monitoring and error detection.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or otherwise obtain; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files." Server log files may contain the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of Data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.

  • Squarespace: Squarespace offers Software as a Service for creating and hosting websites; Service provider: Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.squarespace.com ; Privacy policy: https://www.squarespace.com/privacy ; Data processing agreement: https://www.squarespace.com/dpa . Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://www.squarespace.com/dpa ).

Use of cookies

The term "cookies" refers to functions that store information on and read it from users' devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and user-friendliness of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal regulations. Where necessary, we obtain users' consent beforehand. If consent is not required, we rely on our legitimate interests. This applies when storing and reading information is essential to providing explicitly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online services. Consent can be withdrawn at any time. We provide clear information about the scope of this consent and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage duration:  The following types of cookies are distinguished with regard to storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile application).

  • Persistent cookies: Persistent cookies remain stored even after the user closes their device. This allows, for example, login status to be saved and preferred content to be displayed directly when the user revisits a website. User data collected via cookies can also be used for audience measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these cookies are persistent and can be stored for up to two years.

General information on revocation and objection (opt-out):  Users can revoke their consent at any time and also object to the processing in accordance with legal requirements, including via their browser's privacy settings.

  • Types of data processed: Metadata, communication data and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).

  • Affected persons: Users (e.g., website visitors, users of online services).

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Blogs and publication media

We use blogs or similar online communication and publication tools (hereinafter referred to as "publication medium"). Reader data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. For further information regarding the processing of visitor data to our publication medium, please refer to the privacy policy.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).

  • Affected persons: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Feedback (e.g., collecting feedback via online form); provision of our online services and user-friendliness; provision of contractual services and fulfillment of contractual obligations.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

Contact and inquiry management

When you contact us (e.g. by mail, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the requesting persons is processed to the extent necessary to answer the contact requests and any requested measures.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or image messages and posts, as well as related information such as authorship or time of creation); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).

  • Affected persons: Communication partners.

  • Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online services and user-friendliness.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: When you contact us via our contact form, email, or other communication channels, we process the personal data you provide to answer and process your request. This typically includes information such as your name, contact details, and any other information you provide that is necessary for proper processing. We use this data exclusively for the stated purpose of contacting you and communicating with you; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or on the basis of a legal obligation. If the newsletter's content is specified during the registration process, this content is decisive for the user's consent. Normally, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may ask for your name for a personal greeting in the newsletter or for further information if necessary for the newsletter's purpose.

Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove previously given consent. The processing of this data is limited to the purpose of defending against potential claims. An individual deletion request is possible at any time, provided that the prior existence of consent is confirmed. In cases where we are obligated to permanently respect objections, we reserve the right to store the email address solely for this purpose in a blocklist.

The registration process is logged based on our legitimate interests for the purpose of documenting its proper execution. If we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure email delivery system.

Contents:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); metadata, communication and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).

  • Affected persons: Communication partners.

  • Purposes of processing: Direct marketing (e.g. by email or post).

  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

  • Right to object (opt-out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to receiving further newsletters. You will find a link to unsubscribe at the end of each newsletter, or you can use one of the contact options listed above, preferably email.

Further information on processing procedures, methods and services:

  • Measuring open and click rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server, or its server if we use a mailing service provider, when the newsletter is opened. During this retrieval, technical information, such as details about your browser and system, as well as your IP address and the time of retrieval, are collected. This information is used to technically improve our newsletter based on the technical data or to analyze target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve to identify the reading habits of our users and to adapt our content to them or to send different content according to their interests. The measurement of open and click rates and the storage of the measurement results in user profiles – This text section requires a premium license to unlock. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

  • Mailchimp: Email marketing, automation of marketing processes, collection, storage and management of contact data, measurement of campaign performance, recording and analysis of recipient interaction with content, content personalization; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://mailchimp.com ; Privacy policy: https://mailchimp.com/legal/ ; Data processing agreement: https://mailchimp.com/legal/ ; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (provided by the service provider). Further information: Specific security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/

Management, organization and support tools

We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organizing, managing, planning, and delivering our services. We comply with legal requirements when selecting third-party providers and their services.

Within this framework, personal data may be processed and stored on the servers of third-party providers. This may involve various types of data, which we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data relating to transactions, contracts, other processes, and their content.

If users are referred to third-party providers or their software or platforms in the course of communication, business, or other relationships with us, these third-party providers may process usage data and metadata for security, service optimization, or marketing purposes. We therefore ask you to review the privacy policies of the respective third-party providers.

  • Types of data processed: Content data (e.g., textual or image-based messages and posts, as well as related information such as authorship or creation date); usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved).

  • Affected persons: Communication partners. Users (e.g., website visitors, users of online services).

  • Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Data protection information for whistleblowers

This section provides information on how we handle data from individuals providing information (whistleblowers), as well as from affected and involved parties, within the framework of our whistleblower procedure. Our goal is to offer a straightforward and secure way to report potential misconduct by us, our employees, or service providers, particularly for actions that violate laws or regulations. This text area requires a premium license to unlock.

Legal basis (Germany): Insofar as we process data to fulfill our legal obligations under the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6(1)(c) GDPR and, in the case of special categories of personal data, Article 9(2)(g) GDPR, Section 22 BDSG, in each case in conjunction with Section 10 HinSchG. This relates to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks, and, in the case of using the data collected in the reporting procedure, the initiation of further investigations or employment law proceedings against persons who have been found to have committed a violation.

Insofar as we process data (especially in cases of identified misconduct) within the scope of or for the preparation of legal defense, this is done on the basis of our legitimate interests in lawful and ethical conduct in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

If you have given us your consent to process personal data for specific purposes, the processing is based on this consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR and in the case of special - This text area must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Data types processed:

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

  • Name, contact details and location of the person providing the information,

  • Names and details of possible witnesses or persons affected by the tip,

  • Names and details of the persons against whom the notice is directed,

  • Data on the alleged misconduct,

  • Further relevant details, if provided by the whistleblower.

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

  • Clear identification of the message,

  • Contact details of the informant, if provided,

  • Personal data of persons mentioned in the notice, if provided,

  • Personal data of individuals indirectly affected by the - This text area requires a premium license to unlock. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Special categories of personal data:

It is possible that we may collect special categories of personal data in the course of our activities, particularly when this data is disclosed by a whistleblower. This includes:

  • Health-related data of a person,

  • Data relating to the racial or ethnic origin of persons,

  • Information about a person's religious or philosophical beliefs,

  • Information about a person's sexual orientation.

This data will only be processed if - This text area must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Using our online forms: Please note that you have the option to submit information anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in your browser's 'incognito mode'. Here's how to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

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

The processing of the IP address serves technical and administrative purposes for establishing a connection to our website. It ensures the security, stability, and functionality of the whistleblower form and is an important part of our measures to guarantee confidentiality . This text area must be unlocked with a premium license.

Providing your name: You have the option of submitting information anonymously. However, unless prohibited by national legislation, we recommend providing your name and contact details. This allows us to investigate your report more effectively and, if necessary, contact you directly.

If you provide your name and contact details, your identity will be treated with strict confidentiality. Exceptions to this confidentiality exist only if we are legally obligated to disclose your identity. This may be necessary to protect our rights or the rights of our employees, customers, suppliers, or business partners . This text area requires a premium license to unlock.

Disclosure of data to third parties: We will only disclose data related to submitted reports to third parties under specific circumstances. This occurs either a) if you have given us your explicit consent, or b) if there is a legal obligation to disclose the data. Potential third parties include public authorities, governmental, regulatory, or tax authorities if disclosure is necessary to fulfill a legal or regulatory obligation. Furthermore, we may engage lawyers and other specialist advisors as required by law. These advisors are authorized to investigate suspected misconduct and take necessary measures following an investigation, such as initiating disciplinary or legal proceedings. Additionally, carefully selected and monitored service providers may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obligated to comply with applicable data protection regulations as part of commissioned data processing.

Data Retention and Deletion: Personal data is processed only as long as necessary to fulfill the processing purposes described above. If this data is no longer needed for these purposes, it will be deleted. In certain situations, however, the data may be retained for longer to comply with legal requirements, provided this is necessary and proportionate. In such cases - This text area must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data we process. This data is processed exclusively for the specified purposes. Incoming reports are handled by authorized personnel who receive access to the respective reports and conduct the subsequent investigation of the matter. Our employees are specially trained. - This text area requires a premium license to unlock. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext

  • Data types processed: Inventory data (e.g., full name, home address, contact information, customer number ; this text area requires a premium license to unlock; employee data (information about employees and other individuals within a company); contact data (e.g., postal and email addresses) ; content data (e.g., textual or image-based messages and posts, as well as related information such as authorship details ) . Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with - This text area must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext ).

  • Affected persons: Employees (e.g., staff, applicants, temporary workers, and others - This text area must be unlocked with a premium license. - premiumtext premiumtext premiumtext ); Third parties. Whistleblowers.

  • Purposes of processing: Whistleblower protection.

  • Storage and deletion: Deletion according to the information in the section "General information on data storage and deletion".

  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and updates

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to 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 legally defined, those legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Employees: The term "employees" refers to individuals who are in an employment relationship, whether as staff members, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established through an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various phases, including its establishment, during which the employment contract is concluded; its performance, during which the employee carries out their work; and its termination, when the employment relationship ends, whether through dismissal, a mutual termination agreement, or otherwise. Employee data is all information relating to these individuals and situated within the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance reviews.

  • Inventory data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include, among other things, personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling unambiguous identification and communication.

  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.

  • Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.

  • Conversion tracking: Conversion tracking (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where the marketing measures are implemented and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.

  • Metadata, communication data, and procedural data: These categories contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. It can include details about file size, creation date, document author, and modification history. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs, which are used to track and verify operations.

  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information, revealing how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take through an application. Usage data can also include frequency of use, timestamps 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. Furthermore, 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 referred to as "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 includes information such as timestamps, 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 generate performance reports.

  • Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine when users visit their websites and which content they are interested in. This allows them to better tailor website content to the needs of their visitors. Pseudonymous cookies and web beacons are frequently used for audience analysis purposes to recognize returning visitors and thus obtain more accurate analyses of online service usage.

  • Server monitoring and error detection: We use server monitoring and error detection to ensure the availability and integrity of our online services and to technically optimize them. Performance, utilization, and similar technical metrics are processed, providing information about the stability and any anomalies of our online services. In the event of errors or anomalies, individual user requests are recorded to identify and resolve the source of the problem.

  • Controller: The term "controller" refers to 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 which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.

Created with the free data privacy generator Datenschutz-Generator.de by Dr. Thomas Schwenke