Privacy Memory Map
Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about which types of your personal data (also referred to below simply as "data") we process, for which purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in connection with providing our services and, in particular, on our websites, in mobile applications, and within external online presences such as our social media profiles (collectively referred to below as the "online offering").
The terms used are gender-neutral.
Last updated: May 20, 2026
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transfer of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Provision of the Online Offering and Web Hosting
- Privacy Information for Whistleblowers
- Changes and Updates
- Definitions
Controller
Dennis Michael Heine
Amselweg 4
70794 Filderstadt, Germany
Email address: info@dennis-heine.de
Overview of Processing Activities
The following overview summarizes the types of data processed, the purposes of processing, and the categories of persons affected.
Types of Data Processed
- Inventory data.
- Employee data.
- Contact data.
- Content data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
- Employees.
- Users.
- Third parties.
- Whistleblowers.
Purposes of Processing
- Security measures.
- Provision of our online offering 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 of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or establishment. If more specific legal bases apply in individual cases, we will inform you of them in this privacy policy.
- Consent (Art. 6(1) sentence 1 lit. a GDPR) - The data subject has given consent to the processing of personal data concerning them for one or more specific purposes.
- Legal obligation (Art. 6(1) sentence 1 lit. c GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6(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, provided that the interests, fundamental rights, and freedoms of the data subject requiring the protection of personal data do not override those interests.
National data protection regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). The BDSG contains special rules, among other things, 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, transmission, and automated individual decision-making, including profiling. State data protection laws of the individual federal states may also apply.
Notice regarding applicability of the GDPR and the Swiss FADP: This privacy information is intended 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 terminology of the GDPR is used due to its broader geographical scope and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest", and "particularly sensitive personal data" used in the Swiss FADP, the GDPR terms "processing" of "personal data", "legitimate interest", and "special categories of data" are used. However, where the Swiss FADP applies, the legal meaning of the terms continues to be determined by the Swiss FADP.
Applicability of data protection requirements in the country of establishment: In the country in which the controller has its registered office, national data protection regulations also apply in addition to the General Data Protection Regulation (GDPR).
Security Measures
In accordance with legal requirements and taking into account the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of risks 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, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability, and separation relating to that data. We have also established procedures that ensure the exercise of data subject rights, the deletion of data, and responses to threats to data. Furthermore, we take the protection of personal data into account from the development or selection of hardware, software, and procedures, in line with the principles of data protection by design and data protection by default.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user 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 cornerstones of secure data transmission on the internet. These technologies encrypt 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 high security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and in encrypted form.
Transfer of Personal Data
As part of our processing of personal data, data may be transferred or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks or providers of services and content integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International Data Transfers
Data processing in third countries: If we transfer data to a third country, meaning outside the European Union (EU) or the European Economic Area (EEA), or if this occurs through the use of third-party services or the disclosure or transfer of data to other persons, bodies, or companies (which may be identifiable from the postal address of the respective provider or where this privacy policy expressly refers to data transfers to third countries), this is always done in accordance with 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 European Commission dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the European Commission and establish 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. If changes occur within the framework of the DPF, the standard contractual clauses apply as a reliable fallback option. This helps ensure that your data remains adequately protected even in the event of political or legal changes.
For 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 U.S. Department of Commerce at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions is available from the European Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is withdrawn or there is no longer any other legal basis for processing. This applies in cases where the original processing purpose no longer exists or the data is no longer required. Exceptions apply where 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 enforcement or for protecting the rights of other natural or legal persons, must be archived accordingly.
Our privacy information contains additional details on the retention and deletion of data that apply specifically to certain processing operations.
If several retention periods or deletion deadlines apply to a data item, the longest period is decisive. Data that is no longer retained for its originally intended purpose, but instead due to legal requirements or other reasons, is processed by us only for the reasons that justify its retention.
Start of retention periods at the end of the year: If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships in which data is stored, the triggering event is the effective date of 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, particularly under Articles 15 to 21 GDPR:
- Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you that is based on Art. 6(1) lit. e or f GDPR; this also applies to profiling based on those provisions. If 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 insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to receive information about that 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 completion of data concerning you or correction of inaccurate 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, to request restriction of processing of the data.
- Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, in accordance with legal requirements, or to request transmission of that data to another controller.
- Complaint to 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, place of work, or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Provision of the Online Offering and Web Hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (for example page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (for example IP addresses, time information, identification numbers, persons involved). Log data (for example log files relating to logins, retrieval of data, or access times).
- Data subjects: Users (for example website visitors and users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user friendliness; information technology infrastructure (operation and provision of information systems and technical devices such as computers and servers). Security measures.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Further information on processing operations, procedures, and services:
- Provision of the online offering on rented storage space: For providing our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider, also referred to as a web host; Legal bases: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of server log files. Server log files may include the address and name of accessed websites and files, date and time of access, transferred data volumes, notification of successful retrieval, 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, for example to avoid server overload, particularly in the event of abusive attacks such as DDoS attacks, and to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6(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 whose further retention is required for evidentiary purposes is exempt from deletion until the relevant incident has been finally clarified.
Privacy Information for Whistleblowers
- Types of data processed: Inventory data (for example full name, residential address, contact information, customer number, ); employee data (information on employees and other persons in an employment context, ); contact data (for example postal and email addresses or ); content data (for example textual or visual messages and posts, as well as related information such as details of authorship ). Usage data (for example page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with ).
- Data subjects: Employees (for example employees, applicants, temporary staff, and other ); third parties. Whistleblowers.
- Purposes of processing and legitimate interests: Whistleblower protection.
- Retention and deletion: Deletion in accordance with the information in the section "General Information on Data Storage and Deletion".
- Legal bases: Consent (Art. 6(1) sentence 1 lit. a GDPR); legal obligation (Art. 6(1) sentence 1 lit. c GDPR). Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR).
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We update the privacy policy as soon as changes to the data processing activities we carry out make this necessary. We will inform you as soon as the changes require action on your part, such as consent, or any other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and we ask you to verify the information before contacting them.
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Where terms are legally defined, their statutory definitions apply. The following explanations are primarily intended to aid understanding.
- Employees: Employees are persons who are in an employment relationship, whether as workers, staff members, or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. It includes the employer's obligation to pay remuneration to the employee while the employee performs their work. The employment relationship includes various phases, including its establishment, during which the employment contract is concluded, its performance, during which the employee performs their work, and its termination, whether by notice, termination agreement, or otherwise. Employee data is all information relating to these persons and connected to their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance evaluations.
- Inventory data: Inventory data includes essential information required for identifying and managing contractual partners, user accounts, profiles, and similar assignments. This data may include 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 persons and services, institutions, or systems by enabling clear assignment and communication.
- Content data: Content data includes 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, but also includes metadata that provides information about the content itself, 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, telephone numbers, postal addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers.
- Meta, communication, and procedural data: Meta, communication, and procedural data are categories containing information about the way data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It may include file size, creation date, document author, and change histories. Communication data records the exchange of information between users across different channels, such as email traffic, call logs, messages on social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and reviewing operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a broad range of information showing how users use applications, which functions they prefer, how long they remain on particular pages, and which paths they take through an application. Usage data may 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. Usage data also plays an important role in identifying trends, preferences, and possible problem areas within digital offerings.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (the "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 (for example 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 logged in a system or network. This data typically contains 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 create performance reports.
- Controller: A "controller" is the natural or legal person, public authority, agency, or other body that, 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, including collection, evaluation, storage, transmission, or deletion.
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