Privacy Policy

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent within the framework of providing our application.

The terms used are not gender-specific.

As of: 31 March 2023

Table of Contents

• Preamble

• Controller

• Contact Data Protection Officer

• Overview of Processing Activities

• Relevant Legal Bases

• Security Measures

• Transfer of Personal Data

• Data Processing in Third Countries

• Use of Cookies

• Provision of the Online Services and Web Hosting

• Blogs and Publication Media

• Newsletter and Electronic Notifications

• Web Analysis, Monitoring and Optimisation

• Online Marketing

• Affiliate Programmes and Affiliate Links

• Management, Organisation and Operational Tools

• Amendments and Updates to the Privacy Policy

• Rights of Data Subjects

Controller

Gifting Technologies GmbH

The Delta Campus, Donaustraße 44, 12043 Berlin, Germany

Email address:

hello@zugutschein.de

Legal Notice:

www.zugutschein.de/impressum

Contact Data Protection Officer

hello@zugutschein.de

Overview of Processing Activities

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

Types of Data Processed

• Master data.

• Contact details.

• Content data.

• Contract data.

• Usage data.

• Meta, communication and procedural data.

Categories of Data Subjects

• Communication partners.

• Users.

Purposes of Processing

• Provision of contractual services and customer support.

• Security measures.

• Direct marketing.

• Reach measurement.

• Tracking.

• Office and organisational procedures.

• Conversion tracking.

• Affiliate tracking.

• Feedback.

• Marketing.

• Profiles with user-related information.

• Provision of our online services and user-friendliness.

• Information technology infrastructure.

Relevant Legal Bases

Below is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection provisions may apply in your or our country of residence or registered office. Should more specific legal bases be relevant 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.

• 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.

In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Act on Protection against the Abuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, specific regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for employment-related purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships, as well as the consent of employees. Furthermore, state data protection acts of the individual German federal states may apply.

Security Measures

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

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, transmission, safeguarding availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the erasure of data, and responses to data breaches. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and through data-protection-friendly default settings.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organisational units, or persons, or disclosed to them. Recipients of this data may include, for example, service providers tasked with IT tasks or providers of services and content that are 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 that serve to protect your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this will only be done in accordance with legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications, or binding corporate rules (Arts. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Use of Cookies

Cookies are small text files, or other memory records, that store information on terminal devices and read information from terminal devices. For example, to store the login status in a user account, shopping basket contents in an online shop, the content accessed, or functions used within an online offering. Cookies can also be used for various other purposes, e.g. for the functionality, security, and convenience of online services, as well as for compiling analyses of visitor flows.

Information on consent: We use cookies in accordance with statutory regulations. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is, in particular, not required if storing and reading information, including cookies, is strictly necessary in order to provide the user with a telemedia service (i.e. our online service) explicitly requested by them. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process the personal data of users with the aid of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this occurs within the scope of fulfilling our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. The purposes for which cookies are processed by us are explained in the course of this privacy policy or in the context of our consent and processing procedures.

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

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).

• Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the data collected from users with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke any consent given at any time and also object to processing in accordance with legal requirements pursuant to Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g. by disabling the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing operations, procedures, and services:

• Processing of cookie data based on consent: We use a cookie consent management procedure, within the scope of which users' consents to the use of cookies, or the processing operations and providers mentioned within the scope of the cookie consent management procedure, can be obtained, managed, and revoked by users. The declaration of consent is stored so that it does not have to be repeated and to be able to prove consent in accordance with the legal obligation. Storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual details of the providers of cookie management services, the following notes apply: The duration of the storage of consent can be up to two years. In this process, a pseudonymous user identifier is created and stored with the date/time of consent, details on the scope of consent (e.g. which categories of cookies and/or service providers), as well as the browser, system, and end device used.

Provision of the Online Services and Web Hosting

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

• Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: 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 devices (computers, servers, etc.)); Security measures.

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

• For the provision of this website, we use the services of Bubble.io, Bubble Group, Inc., 900 Broadway, Suite 504, New York, NY 10003, USA

Further information on processing operations, procedures, and services:

• Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from an appropriate server provider (also called a "web host"); Legal bases: 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 include the address and name of the retrieved web pages and files, date and time of retrieval, 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 can be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure server utilisation and stability;

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

• Erasure of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is excluded from erasure until the final clarification of the respective incident.

Blogs and Publication Media

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

• Types of data processed: Master data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. visited websites, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Provision of contractual services and customer support; Feedback (e.g. collecting feedback via online form); Provision of our online services and user-friendliness.

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

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or legal permission. Insofar as the contents of the newsletter are specifically described in the context of registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal address in the newsletter, or other details if these are necessary for the purposes of the newsletter.

Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Likewise, changes to your data stored with the mailing service provider are logged.

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 a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a blocklist solely for this purpose.

The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving its proper implementation. Where we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system.

Contents:

Information about us, our services, promotions, and offers.

• Types of data processed: Master data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status); Usage data (e.g. visited websites, interest in content, access times).

• Data subjects: Communication partners; Users (e.g. website visitors, users of online services).

• Purposes of processing: Direct marketing (e.g. by email or post); Provision of contractual services and customer support.

• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

• Opt-out option: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email, for this purpose.

Further information on processing operations, procedures, and services:

• Measurement of open and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of our delivery service provider if we use one. In the context of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is collected initially. This information is used for the technical improvement of our newsletter based on technical data or target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until deleted. The evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open rates and click rates, as well as the storage of measurement results in user profiles Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

• Condition for the use of free services: Consent to the sending of mailings may be made a condition for the use of free services (e.g. access to certain content or participation in certain campaigns). If users wish to make use of the free service without subscribing to the newsletter, please contact us.

Web Analysis, Monitoring and Optimisation

Web analysis (also referred to as "reach measurement") is used to evaluate visitor flows to our online services and can include behaviour, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online service or its functions or contents are used most frequently or invite repeated use. Likewise, we can understand which areas require optimisation.

In addition to web analysis, we can also use testing procedures, e.g. to test and optimise different versions of our online service or its components.

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

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. Generally, within the scope of web analysis, A/B testing, and optimisation, no clear data of users (such as email addresses or names) is stored, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

• Types of data processed: Usage data (e.g. visited websites, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles); Tracking (e.g. interest-/behaviour-based profiling, use of cookies); Provision of our online services and user-friendliness.

• Security measures: IP masking (pseudonymisation of the IP address).

• Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures, and services:

• Google Analytics: Web analysis, reach measurement and measurement of user flows; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (guaranteeing the level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

• Google Analytics 4: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to allocate analytical information to an end device in order to determine what content users have accessed within one or several usage sessions, what search terms they used, whether they revisited these, or whether they interacted with our online service. The time of use and its duration are also stored, as well as the sources of users referring to our online offering and technical aspects of their end devices and browsers. In doing so, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. In Analytics, higher-level geographic location data is provided by collecting the following metadata based on IP lookups: "City" (and the derived city latitude and longitude), "Continent", "Country", "Region", "Subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The user's IP address is not logged and is shortened by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is processed via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard Contractual Clauses (guaranteeing the level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

• Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (reference is made to further details in this privacy policy). Therefore, the Tag Manager itself (which implements the tags) does not yet create user profiles or store cookies, for example. Google only receives the user's IP address, which is necessary to run Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (guaranteeing the level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms.

Online Marketing

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the display of promotional and other content (collectively referred to as "Content") based on potential user interests, as well as measuring their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used by means of which the user information relevant to the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical details, such as the browser used, the computer system used, and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by truncating the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored within the scope of the online marketing procedure, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure, analysed for the purpose of displaying content, supplemented with other data, and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network connects the users' profiles with the aforementioned details. We ask you to note that users can enter into additional agreements with the providers, e.g. through consent given during registration.

As a matter of principle, we only obtain access to aggregated information about the performance of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract being concluded with us. Conversion tracking is used solely to analyse the success of our marketing measures.

Unless stated otherwise, we ask you to assume that cookies used are stored for a period of two years.

• Types of data processed: Usage data (e.g. visited websites, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Tracking (e.g. interest-/behaviour-based profiling, use of cookies); Marketing; Profiles with user-related information (creation of user profiles); Conversion measurement (measuring the effectiveness of marketing measures).

• Security measures: IP masking (pseudonymisation of the IP address).

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

• Opt-out option: We refer to the privacy policies of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option was specified, there is on the one hand the possibility that you disable cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered in summary for respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.

Further information on processing operations, procedures, and services:

• Google Ads and conversion tracking: Online marketing procedure for the purpose of placing content and advertisements within the service provider's advertising network (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. Furthermore, we measure the conversion of the advertisements, i.e. whether users took them as an opportunity to interact with the ads and make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Controller-controller data protection terms and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

• Google AdSense with personalised ads: We use the service Google AdSense with personalised ads, with the help of which ads are displayed within our online offering and we receive remuneration for their display or other use; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Terms on data processing for Google advertising products: Information on the services Controller-controller data protection terms and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

• Google AdSense with non-personalised ads: We use the service Google AdSense with non-personalised ads, with the help of which ads are displayed within our online offering and we receive remuneration for their display or other use; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Google Ads Controller-Controller Data Protection Terms and standard contractual clauses for data transfers to third countries: https://business.safety.google/adscontrollerterms.

Affiliate Programmes and Affiliate Links

We integrate so-called affiliate links or other references (which may include, for example, search masks, widgets, or discount codes) to the offers and services of third-party providers into our online offering (collectively referred to as "affiliate links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary for the respective third-party providers to learn that users followed an affiliate link used within our online offering. The assignment of the affiliate links to the respective business transactions or other actions (e.g. purchases) serves solely the purpose of commission accounting and is cancelled as soon as it is no longer required for this purpose.

For the purposes of the aforementioned assignment of the affiliate links, the affiliate links can be supplemented by certain values that are a component of the link or can be stored otherwise, e.g. in a cookie. The values may include, in particular, the originating website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, the data of users is processed on the basis of our legitimate interests (i.e. interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

• Types of data processed: Contract data (e.g. subject matter of contract, term, customer category); Usage data (e.g. visited websites, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: Users (e.g. website visitors, users of online services).

• Purposes of processing: Affiliate tracking.

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

Further information on processing operations, procedures, and services:

• Agoda.com Partner Programme: Affiliate marketing partner programme; Service provider: Agoda Company Pte. Ltd., 30 Cecil Street Prudential Tower #19-08, Singapore 049712; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.agoda.com/de-de; Privacy Policy: https://www.agoda.com/de-de/info/agoda-privacy.html.

• Amazon Partner Programme: Affiliate partner programme (Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliated companies); Service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.amazon.de; Privacy Policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010.

• Awin.com Partner Programme: Affiliate marketing partner programme; Service provider: AWIN AG Landsberger Allee 104 BC 10249 Berlin; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.awin.com/de; Privacy Policy: https://www.awin.com/de/datenschutzerklarung

Management, Organisation and Operational Tools

We use services, platforms, and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organising, administering, planning, and providing our services. When selecting third-party providers and their services, we comply with legal requirements.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes, and their contents.

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

• Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. visited websites, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, consent status).

• Data subjects: Communication partners; Users (e.g. website visitors, users of online services).

• Purposes of processing: Provision of contractual services and customer support; Office and organisational procedures.

Amendments and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another individual notification.

Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the details before contacting us.

Rights of Data Subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR, including 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 the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

• Right to withdraw consent: You have the right to withdraw consent at any time.

• Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with statutory requirements.

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

• Right to erasure and restriction of processing: You have the right, in accordance with statutory provisions, to demand that data concerning you be erased without undue delay or, alternatively, to demand restriction of the processing of the data in accordance with statutory provisions.

• 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 statutory requirements, or to demand its transmission to another controller.

• Lodging 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 provisions of the GDPR.