Ai3X App – Privacy Policy

Privacy Policy

 

Preamble

With the following privacy policy we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for which purposes and to what extent in the context of providing our application, in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

This privacy policy applies to the use of our mobile app “Ai3X” for iOS by users who are located in the United Kingdom.

The terms used are not gender-specific.

Last Update: 13 March 2026

 

Table of contents

• Preamble

• Controller

• Overview of processing operations

• Relevant legal bases

• Security Precautions

• Transmission of Personal Data

• International data transfers

• General Information on Data Retention and Deletion

• Rights of Data Subjects

• Business services

• Business processes and operations

• Use of online platforms for listing and sales purposes

• Provision of online services and web hosting

• Processing of Data within the Application (App)

• Purchase of applications via Appstores

• Registration, Login and User Account

• Single Sign-on Authentication

• Contact and Inquiry Management

• Artificial Intelligence (AI)

• Cloud Services

• Web Analysis, Monitoring and Optimization

• Management, Organization and Utilities

• Changes and Updates

• Terminology and Definitions

 

Controller

Ai3X GmbH (hereinafter “Ai3X”, “we”, “us”) is the data controller within the meaning of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018:
Kleine Brückenstraße 3
60594 Frankfurt am Main
Germany

Authorised Representatives: Philipp Haßdenteufel

E-mail address: support@ai3xapp.com

Phone: +4915123800065

Legal Notice: https://www.ai3xapp.com/imprint-en

UK GDPR Representative (Article 27)
If you are located in the UK, and have questions or concerns regarding your personal data, you may contact our GDPR representative:

UK Representative:
Euverify Ltd (UK),
3rd Floor, 86-90 Paul Street
London, EC2A 4NE
United Kingdom

Email: gdpr@euverify.com

To submit a Data Subject Access Request (DSAR), data deletion request, or any other GDPR-related inquiry, please use our secure portal at:
https://gdpr.euverify.com/verify/73a90bca-8192-475f-a043-400c4fd4f12c

This link allows you to verify our appointed representative and submit GDPR requests directly. Requests submitted through this portal are logged and tracked to ensure timely response and compliance.

 

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

 

Categories of Processed Data

• Inventory data.

• Payment Data.

• Contact data.

• Content data.

• Contract data.

• Usage data.

• Meta, communication and process data.

• Log data.

 

Categories of Data Subjects

• Service recipients and clients.

• Employees.

• Prospective customers.

• Communication partner.

• Users.

• Business and contractual partners.

• Education and course participants.

• Third parties.

 

Purposes of Processing

• Provision of contractual services and fulfillment of contractual obligations.

• Communication.

• Security measures.

• Web Analytics.

• Office and organisational procedures.

• Conversion tracking.

• Organisational and Administrative Procedures.

• Feedback.

• Marketing.

• Profiles with user-related information.

• Authentication processes.

• Provision of our online services and usability.

• Information technology infrastructure.

• Financial and Payment Management.

• Public relations.

• Sales promotion.

• Business processes and management procedures.

• Artificial Intelligence (AI).

 

Relevant legal bases

Relevant legal bases under the UK GDPR: In the following, you will find an overview of the legal bases under the UK General Data Protection Regulation (“UK GDPR”) on which we base the processing of personal data. Where the EU General Data Protection Regulation (“GDPR”) applies in parallel, the corresponding provisions largely mirror those of the UK GDPR. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in this privacy policy.

• Consent (Article 6 (1) (a) UK GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

• Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

• Compliance with a legal obligation (Article 6 (1) (c) UK GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.

• Legitimate Interests (Article 6 (1) (f) UK GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in the United Kingdom: In addition to the data protection provisions of the UK GDPR, national regulations apply to data protection in the United Kingdom. These include in particular the Data Protection Act 2018 as well as the Privacy and Electronic Communications (EC Directive) Regulations 2003 (“PECR”). In particular, PECR contains specific provisions on electronic communications, the use of cookies and similar technologies and direct marketing. Depending on the circumstances of the processing, these and other sector-specific rules may apply in addition to the UK GDPR.

Other applicable data protection laws: As Ai3X GmbH is established in Germany and also offers its services within the European Economic Area (EEA), the EU GDPR and national data protection laws of EU Member States (such as the German Federal Data Protection Act – “BDSG”) may apply in parallel to certain processing activities. In such cases, we ensure that the requirements of all applicable data protection regimes are complied with.

Reference to the applicability of the UK GDPR and other data protection regimes: This privacy policy is primarily intended to provide information pursuant to the UK GDPR and the Data Protection Act 2018 for users located in the United Kingdom. For reasons of clarity and consistency, we generally use the terminology of the UK GDPR, such as “processing”, “personal data”, “legitimate interests” and “special categories of personal data”. Where the EU GDPR or other data protection legislation applies in parallel, the corresponding concepts are to be understood in accordance with the respective applicable law.

 

Security Precautions

We take appropriate technical and organisational measures in accordance with the applicable legal requirements, in particular under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, 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 risk of varying likelihood and severity for the rights and freedoms of natural persons, in order 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 access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect the data of users transmitted via our online services from unauthorised access, we employ 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 that is transferred between the website or app and the user's browser (or between two servers), thereby safeguarding the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions conform to 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 securely and encryptedly transmitted.

 

Transmission of Personal Data

In the course of processing personal data, it may happen that such data is transmitted to, or disclosed to, other entities, companies, legally independent organisational units, or individuals. Recipients of this data may include, in particular, service providers tasked with IT duties or providers of services and content that are integrated into a website or app. In such cases, we observe the applicable legal requirements, in particular those under the UK GDPR and the Data Protection Act 2018, and we conclude appropriate contracts or agreements (such as data processing agreements) with the recipients of your data, where required, in order to protect your personal data.

 

International data transfers

Data processing in third countries: If we transfer personal data to a country outside the United Kingdom, or if this occurs in the context of using third-party services or disclosing data to other persons, entities or companies (which is apparent either from the provider’s address or from explicit information in this privacy policy), this is always done in accordance with the applicable legal requirements on international data transfers.

For data transfers from the UK to the USA, we primarily rely on the UK extension to the EU–U.S. Data Privacy Framework (the “UK–US Data Bridge”) adopted by the UK Government as an adequacy decision under the UK GDPR. Where necessary, we also use appropriate safeguards such as the UK International Data Transfer Agreement (“IDTA”) or the UK International Data Transfer Addendum to the EU Commission’s Standard Contractual Clauses (“UK Addendum”), which set out contractual obligations to protect your data.

This layered approach ensures comprehensive protection of your data: the UK–US Data Bridge serves as the primary transfer mechanism where the recipient is appropriately certified, while the IDTA or UK Addendum (and, where relevant, the underlying EU Standard Contractual Clauses) function as additional safeguards or fallback options. This is intended to ensure that your data remains adequately protected even in the event of political or legal changes affecting one particular transfer mechanism.

For individual service providers, we will indicate whether they participate in the Data Privacy Framework (and, where applicable, its UK extension) and whether we also rely on contractual safeguards such as the IDTA, UK Addendum or Standard Contractual Clauses. The list of certified companies and further information about the Data Privacy Framework and its UK extension can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/.

For data transfers from the UK to other third countries, we rely, where available, on UK adequacy regulations adopted by the UK Government. If no such adequacy decision exists, we implement appropriate safeguards, in particular the IDTA, the UK Addendum used together with the EU Standard Contractual Clauses, binding corporate rules, explicit consent of the data subject, or transfers that are necessary for the performance of a contract, the establishment, exercise or defence of legal claims or for important reasons of public interest, in each case in accordance with the requirements of the UK GDPR and the Data Protection Act 2018.

In our detailed data protection notices for individual services, we will inform you which transfer mechanisms (adequacy decision, IDTA/UK Addendum, Standard Contractual Clauses or other safeguards) are used for the respective provider and destination country.

Disclosure of personal data abroad under other data protection regimes: As Ai3X GmbH is established in Germany and also offers its services within the European Economic Area (EEA) and Switzerland, certain processing activities may additionally be subject to the EU General Data Protection Regulation (“EU GDPR”) and/or the Swiss Federal Act on Data Protection (“FADP”). Where this is the case, we ensure that disclosures of personal data abroad also comply with the relevant requirements of these legal frameworks (for example, EU adequacy decisions or the Swiss list of states with an adequate level of data protection).

For data transfers to the USA that fall under the EU GDPR, we primarily rely on the EU–U.S. Data Privacy Framework, which the European Commission has recognised as providing an adequate level of protection for transfers of personal data from the EU to certified U.S. organisations. In addition, we may conclude the EU Commission’s Standard Contractual Clauses with providers in third countries in order to establish contractual obligations to protect your data.

This combination of adequacy decisions (such as the EU–U.S. Data Privacy Framework) and Standard Contractual Clauses is designed to provide a high level of protection for personal data transferred from the EEA, while also ensuring legal continuity if one of these mechanisms is modified, restricted or invalidated.

For individual service providers, we will indicate whether they are certified under the relevant part of the Data Privacy Framework (for example, the EU–U.S. or Swiss–U.S. frameworks) and whether Standard Contractual Clauses or comparable safeguards are in place. The list of certified companies and further information about the Data Privacy Framework can be found at https://www.dataprivacyframework.gov/.

For data transfers to other third countries that are subject to the EU GDPR or the FADP, appropriate safeguards are used, in particular EU Standard Contractual Clauses, binding corporate rules, specific contractual guarantees or other mechanisms recognised by the competent supervisory authorities. Where necessary, we also carry out transfer risk assessments and implement additional technical and organisational measures to protect the data.

Under the FADP, disclosures of personal data abroad are permitted where the recipient country ensures an adequate level of protection or appropriate safeguards have been implemented, and in certain exceptional cases, for example where the data subject has expressly consented, the disclosure is directly connected with the conclusion or performance of a contract, is necessary to protect an overriding public interest or for the establishment, exercise or enforcement of legal claims, or concerns personal data that the data subject has made generally accessible and has not expressly objected to its processing.

We will inform you in our privacy notices which of our service providers rely on the Data Privacy Framework (including its UK extension) or other adequacy decisions, and where additional safeguards such as the IDTA, UK Addendum or Standard Contractual Clauses are used for international data transfers.

 

General Information on Data Retention and Deletion

We delete personal data that we process in accordance with the applicable legal regulations as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies in particular where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist if statutory obligations or overriding legitimate interests require a longer retention or archiving of the data (for example obligations under commercial or tax law or the need to establish, exercise or defend legal claims). This applies accordingly under the UK General Data Protection Regulation (“UK GDPR”), the UK Data Protection Act 2018 and other applicable national laws (such as German and, where relevant, Swiss commercial and tax law).

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

Our privacy notices contain additional information on the retention and deletion of data specifically applicable to certain processing activities.

In cases where multiple retention periods or deletion deadlines for data are specified, the longest period always prevails.

Data that is no longer stored for its originally intended purpose but is retained due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.

Data Retention and Deletion: The following general deadlines apply for the retention and archiving according to German law:

• 10 Years - Fiscal Code/Commercial Code - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the necessary work instructions and other organisational documents (Section 147 Paragraph 1 No. 1 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 14b Paragraph 1 of the German VAT Act (UStG), Section 257 Paragraph 1 No. 1 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).

• 8 years - Accounting documents, such as invoices, booking and expense receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).

• 6 Years - Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, and other documents to the extent that they are significant for taxation purposes, for example, hourly wage slips, operating accounting sheets, calculation documents, price tags, as well as payroll accounting documents, provided they are not already accounting vouchers and cash register tapes (Section 147 Paragraph 1 No. 2, 3, 5 in conjunction with Paragraph 3 of the German General Tax Code (AO), Section 257 Paragraph 1 No. 2 and 3 in conjunction with Paragraph 4 of the German Commercial Code (HGB)).

• 3 Years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experiences and common industry practices, will be stored for the duration of the regular statutory limitation period of three years. This period begins at the end of the year in which the relevant contractual transaction took place or the contractual relationship ended in the case of ongoing contracts (Sections 195, 199 of the German Civil Code).

Data Retention and Deletion: The following general retention and archiving periods apply under Swiss law:

• 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balances, accounting vouchers and invoices, as well as all necessary working instructions and other organizational documents (Article 958f of the Swiss Code of Obligations (OR)).

• 10 years - Data necessary to consider potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on previous business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Articles 127, 130 OR). Claims for rent, lease, and interest on capital, as well as other periodic services, for the delivery of food, for board and lodging, for innkeeper debts, as well as for craftsmanship, small-scale sales of goods, medical care, professional services by lawyers, legal agents, procurators, and notaries, and from the employment relationship of employees, expire after five years (Article 128 OR).

Start of the period at the end of the year: If a period does not expressly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the termination or other termination of the legal relationship takes effect.

Review and compliance with deletion periods: Compliance with legal and internal requirements regarding the deletion of personal data is regularly reviewed. It is ensured that all personal data no longer needed or whose storage period has expired are deleted in accordance with relevant data protection regulations or, in the case of archiving and retention obligations, processing is restricted to these purposes. These reviews of deletion processes and compliance with established deletion periods occur regularly, at least once a year. The results of the review are documented and evaluated by the person(s) responsible for the deletion review. Upon identification of deviations, corrective actions are immediately initiated, and the effectiveness of these measures is evaluated in subsequent reviews to ensure ongoing compliance, including with the storage limitation principle under Article 5(1)(e) UK GDPR.

 

Rights of Data Subjects

Rights of the data subjects under the UK GDPR: As a data subject, you are entitled to various rights under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018, which arise in particular from Articles 15 to 21 UK GDPR and the relevant national provisions:

• Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data which is based on point (e) or (f) of Article 6(1) UK GDPR, including profiling based on those provisions. Where personal data are 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, which includes 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. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

• Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to access the personal data and receive further information and a copy of the data in accordance with the legal provisions.

• Right to rectification: You have the right, in accordance with the law, to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.

• Right to erasure and right to restriction of processing: In accordance with the statutory provisions, you have the right to obtain the erasure of personal data concerning you without undue delay or, alternatively, to obtain restriction of processing of your personal data where the legal requirements are met.

• Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements, and to have those data transmitted to another controller where this is technically feasible.

• 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 data protection supervisory authority if you consider that the processing of personal data relating to you infringes data protection law. In the United Kingdom, the competent authority is the Information Commissioner’s Office (ICO). Depending on the circumstances and where other data protection regimes (such as the EU GDPR) apply in parallel, you may also have the right to lodge a complaint with another competent supervisory authority.

Rights of the data subjects under the Swiss Federal Act on Data Protection (FADP):

Where the Swiss Federal Act on Data Protection (“FADP”) applies to the processing of your personal data, you have the following rights in accordance with its provisions:

• Right to information: You have the right to request confirmation as to whether personal data concerning you are being processed, and to receive the information necessary for you to assert your rights under the FADP and to ensure transparent data processing.

• Right to data release or transfer: You have the right to request the release of your personal data, which you have provided to us, in a common electronic format, as well as its transfer to another data controller, provided this does not require disproportionate effort.

• Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.

• Right to object, deletion and destruction: You have the right to object to the processing of your data, as well as to request that personal data concerning you be deleted or destroyed, in accordance with the requirements of the FADP.

 

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

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

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract object, duration, customer category).

• Data subjects: Service recipients and clients; Prospective customers; Business and contractual partners. Education and course participants.

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Communication; Office and organisational procedures; Organisational and Administrative Procedures. Business processes and management procedures.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR); Compliance with a legal obligation (Article 6 (1) (c) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Education and Training Services: We process the data of the participants of our education and training programmes (uniformly referred to as " students") in order to provide them with our educational and training services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and educational relationship. The processing also includes the performance evaluation and evaluation of our services and the teachers and instructors.
  
  As part of our activities, we may also process special categories of data, in particular information on the health of persons undergoing training or further training and data revealing ethnic origin, political opinions, religious or philosophical convictions. To this end, we obtain, if necessary, the express consent of the students to be trained and further educated and process the special categories of data otherwise only if it is necessary for the provision of training services, for purposes of health care, social protection or protection of vital interests of the students to be trained and further educated; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

• Software and Platform Services: We process the data of our users, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our offer and to develop it further. The required details are identified as such within the context of the conclusion of the agreement, order or comparable contract and include the details required for the provision of services and invoicing as well as contact information in order to be able to hold any further consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

 

Business processes and operations

Personal data of service recipients and clients - including customers, clients, or in specific cases, mandates, patients, or business partners as well as other third parties - are processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relations. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting, and project management.

The collected data is used to fulfil contractual obligations and make business processes efficient. This includes the execution of business transactions, the management of customer relationships, the optimisation of sales strategies, and ensuring internal invoicing and financial processes. Additionally, the data supports the protection of the rights of the controller and promotes administrative tasks as well as the organisation of the company.

Personal data may be transferred to third parties if necessary for fulfilling the mentioned purposes or legal obligations. After legal retention periods expire or when the purpose of processing no longer applies, the data will be deleted. This also includes data that must be stored for longer periods due to tax law and legal obligations to provide evidence.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Contract data (e.g. contract object, duration, customer category); Log data (e.g. log files concerning logins or data retrieval or access times.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

• Data subjects: Service recipients and clients; Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners; Third parties; Users (e.g. website visitors, users of online services). Employees (e.g. employees, job applicants, temporary workers, and other personnel.).

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures; Business processes and management procedures; Communication; Marketing; Sales promotion; Public relations; Financial and Payment Management. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)).

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR); Legitimate Interests (Article 6 (1) (f) UK GDPR); Compliance with a legal obligation (Article 6 (1) (c) UK GDPR).

Further information on processing methods, procedures and services used:

• Contact management and contact maintenance: Processes required in the context of organizing, maintaining, and securing contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training employees in effective use of contact management software, regular review of communication history and adjustment of contact strategies); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR), Legitimate Interests (Article 6 (1) (f) UK GDPR).

• General Payment Transactions: Procedures required for carrying out payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, management of chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR), Legitimate Interests (Article 6 (1) (f) UK GDPR).

• Accounting, accounts payable, accounts receivable: Procedures required for the collection, processing, and control of business transactions in the area of accounts payable and receivable accounting (e.g., creation and verification of incoming and outgoing invoices, monitoring and management of outstanding items, execution of payment transactions, handling of dunning processes, account reconciliation within the scope of receivables and payables, accounts payable accounting, and accounts receivable accounting); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR), Compliance with a legal obligation (Article 6 (1) (c) UK GDPR), Legitimate Interests (Article 6 (1) (f) UK GDPR).

• Financial Accounting and Taxes: Procedures required for the collection, management, and control of finance-related business transactions as well as for the calculation, reporting, and payment of taxes (e.g., accounting and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, handling of dunning processes, account reconciliation, tax consulting, preparation and submission of tax returns, management of tax affairs); Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR), Compliance with a legal obligation (Article 6 (1) (c) UK GDPR), Legitimate Interests (Article 6 (1) (f) UK GDPR).

• Marketing, advertising, and sales promotion: Processes required in the context of marketing, advertising, and sales promotion (e.g., market analysis and audience targeting, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

• Public Relations: Processes required in the context of public relations and public relations activities (e.g., development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and corporate websites, management of corporate branding); Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

 

Use of online platforms for listing and sales purposes

We offer our services on online platforms operated by other service providers. In addition to our privacy policy, the privacy policies of the respective platforms apply. This is particularly true with regard to the payment process and the methods used on the platforms for performance measuring and behaviour-related marketing.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

• Data subjects: Service recipients and clients. Business and contractual partners.

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Marketing. Business processes and management procedures.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Apple App Store: App and software distribution platform; Service provider: Apple Distribution International Limited, Hollyhill Industrial Estate, Hollyhill, Cork, Ireland (for users in the United Kingdom, personal data relating to the App Store is generally controlled by Apple Distribution International Limited in accordance with Apple’s privacy policy); Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.apple.com/app-store/. Privacy Policy: https://www.apple.com/privacy/privacy-policy/.

 

Provision of online services and web hosting

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

• Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties). Log data (e.g. log files concerning logins or data retrieval or access times.).

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

• Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.)). Security measures.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Provision of online offer on rented hosting space: For the provision of our online services, 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 hoster"); Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

• Collection of Access Data and Log Files: Access to our online service is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volumes, notification of successful retrieval, browser type along with version, the user's operating system, referrer URL (the previously visited page), and typically IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, known as DDoS attacks), and to ensure server load management and stability; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR). Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

 

Processing of Data within the Application (App)

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Payment Data (e.g. bank details, invoices, payment history). Contract data (e.g. contract object, duration, customer category).

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

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Commercial use: We process the data of the users of our application, registered and any test users (hereinafter uniformly referred to as "users") in order to provide them with our contractual services and on the basis of legitimate interests to ensure the security of our application and to develop it further. The required details are identified as such within the scope of the conclusion of a contract for the use of the application, the conclusion of an order, an order or a comparable contract and may include the details required for the provision of services and any invoicing as well as contact information in order to be able to hold any consultations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

• Storage of an own unique identifier: In order to provide the application and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no clear data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated during the installation of the application, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.

 

Purchase of applications via Appstores

The purchase of our apps is done via special online platforms operated by other service providers (so-called "appstores"). In this context, the data protection notices of the respective appstores apply in addition to our data protection notices. This applies in particular with regard to the methods used on the platforms for webanalytics and for interest-related marketing as well as possible costs.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

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

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations. Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Apple App Store: App and software distribution platform; Service provider: Apple Distribution International Limited, Hollyhill Industrial Estate, Hollyhill, Cork, Ireland (for users in the United Kingdom, personal data relating to the App Store is generally controlled by Apple Distribution International Limited in accordance with Apple’s privacy policy); Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.apple.com/app-store/. Privacy Policy: https://www.apple.com/privacy/privacy-policy/.

 

Registration, Login and User Account

Users can create a user account. Within the scope of registration, the required mandatory information is communicated to the users and processed for the purposes of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address).

Within the scope of using our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by e-mail of information relevant to their user account, such as technical changes.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Log data (e.g. log files concerning logins or data retrieval or access times.).

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

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organisational and Administrative Procedures. Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Firebase Authentication: Authentication of users, management of user accounts, password reset, email/password login, login with third-party providers such as “Sign in with Apple”, session management and monitoring of suspicious activities; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Website: https://firebase.google.com/products/auth. Privacy Policy: https://policies.google.com/privacy.

• Registration with pseudonyms: Users may use pseudonyms as user names instead of real names; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

• Users' profiles are public: The users' profiles are not publicly visible or accessible.

• Deletion of data after termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

• No obligation to retain data: It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

 

Single Sign-on Authentication

"Single Sign-On" or "Single Sign-On Authentication or Logon" are procedures that allow users to log in to our online services using a user account with a provider of Single Sign-On services (e.g. a social network). The prerequisite for Single Sign-On Authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the online form provided for this purpose, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via the button.

Authentication takes place directly with the respective single sign-on provider. Within the scope of such authentication, we receive a user ID with the information that the user is logged in with the respective single sign-on provider under this user ID and an ID that cannot be used for other purposes (so-called "user handle"). Whether we receive further data depends solely on the single sign-on procedure used, the data releases selected as part of authentication and also which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, there can be different data, usually the e-mail address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is neither visible to us nor is it stored by us.

Users are requested to note that their data stored with us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actual. If, for example, the e-mail addresses of users change, users must change these manually in their user account with us.

We can use single sign-on authentication, provided that it has been agreed with users in the context of pre-fulfilment or fulfilment of the contract, in the context of consent processing and otherwise use it on the basis of our legitimate interests and the interests of users in an effective and secure authentication system.

Should users decide to no longer want to use the link of their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this link within their user account with the Single Sign-On provider. If users wish to delete their data from us, they must cancel their registration with us.

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

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

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Security measures; Authentication processes. Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Deletion after termination.

• Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Apple Single-Sign-On: Authentication services for user logins, provision of single sign-on functionalities, management of identity information and application integrations; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.apple.com. Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.

 

Contact and Inquiry Management

When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

• Processed data types: Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties).

• Data subjects: Communication partner (Recipients of e-mails, letters, etc.).

• Purposes of processing: Communication; Organisational and Administrative Procedures; Feedback (e.g. collecting feedback via online form). Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR). Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR).

Further information on processing methods, procedures and services used:

• Cloud Firestore: Storage and processing of support and deletion requests (in particular for the analytics opt-out function) in a cloud database in order to technically receive messages sent from the app and automatically forward them as e-mails to our support team. The contents of the messages (e.g. e-mail address, PostHog ID, free-text request, technical metadata) are stored on Google’s servers and are regularly deleted once the request has been processed. The legal bases are performance of a contract or pre-contractual steps (Article 6 (1) (b) UK GDPR) for support requests and our legitimate interests in the efficient and secure handling of user enquiries (Article 6 (1) (f) UK GDPR); Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Website: https://firebase.google.com/products/storage. Privacy Policy: https://policies.google.com/privacy.

• Contact form: Upon contacting us via our contact form, email, or other means of communication, we process the personal data transmitted to us for the purpose of responding to and handling the respective matter. This typically includes details such as name, contact information, and possibly additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) UK GDPR), Legitimate Interests (Article 6 (1) (f) UK GDPR).

 

Artificial Intelligence (AI)

We use artificial intelligence (AI), which involves the processing of personal data. The specific purposes and our interest in using AI are mentioned below. According to the term "AI system", as defined for example in Article 3 No. 1 of the EU Artificial Intelligence Act, we understand AI to be a machine-based system designed for varying degrees of autonomous operation, capable of adaptation after deployment, and producing outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments.

Our AI systems are used in strict compliance with legal requirements. These include, where applicable, specific regulations for artificial intelligence as well as data protection requirements, in particular the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018. In particular, we adhere to the principles of lawfulness, transparency, fairness, human oversight, purpose limitation, data minimisation, integrity and confidentiality. We ensure that the processing of personal data is always based on a legal foundation. This may either be the consent of the data subjects or a statutory permission.

When using external AI systems, we carefully select their providers (hereinafter referred to as "AI providers"). In accordance with our legal obligations, we ensure that the AI providers comply with applicable provisions. We also observe our duties when using or operating the acquired AI services. The processing of personal data by us and the AI providers is carried out exclusively on the basis of consent or legal authorisation. We place particular emphasis on transparency, fairness and maintaining human oversight over AI-supported decision-making processes.

To protect processed data, we implement appropriate and robust technical as well as organisational measures. These ensure the integrity and confidentiality of processed data and minimise potential risks. Through regular reviews of AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.

• Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).

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

• Purposes of processing: Artificial Intelligence (AI).

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Microsoft Azure OpenAI Service: Interface access (so-called "API") to AI-based services designed to understand and generate natural language and related inputs, analyze information, and make predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the legal sense of the term as applicable). The provision of AI services includes the processing (including collection, storage, organization, and structuring) of personal data as part of a machine learning process based on natural language; conducting activities to verify or maintain the quality of the services; identifying and correcting errors that impair the existing intended functionality, as well as supporting efforts to ensure the security and integrity of the AI services; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://azure.microsoft.com/en-gb/products/ai-foundry/models/openai/; Privacy Policy: https://www.microsoft.com/en-us/privacy/privacystatement; Data Processing Agreement: https://azure.microsoft.com/en-us/support/legal/. Basis for third-country transfers: United Kingdom – UK Extension to the EU–U.S. Data Privacy Framework (“UK–U.S. Data Bridge”), the International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses; EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/en-us/support/legal/); Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://azure.microsoft.com/en-us/support/legal/).

• Claude API: AI-based service designed to understand and generate natural language and related inputs, analyze information, and make predictions ("AI", i.e., "Artificial Intelligence", is to be understood in the legal sense of the term as applicable). The provision of AI services includes the processing (including collection, storage, organization, and structuring) of personal data as part of a machine learning process based on natural language; conducting activities to verify or maintain the quality of the services; identifying and correcting errors that may impair the intended functionality, as well as supporting efforts to ensure the security and integrity of the AI services; Service provider: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.anthropic.com/; Privacy Policy: https://www.anthropic.com/legal/privacy; Data Processing Agreement: https://www.anthropic.com/legal/commercial-terms. Basis for third-country transfers: United Kingdom – International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses; EEA – Standard Contractual Clauses (https://www.anthropic.com/legal/commercial-terms); Switzerland – Standard Contractual Clauses (https://www.anthropic.com/legal/commercial-terms).

 

Cloud Services

We use Internet-accessible software services (so-called "cloud services", also referred to as "Software as a Service") provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider's servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users' devices for web analysis or to remember user settings (e.g. in the case of media control).

• Processed data types: Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers); Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.). Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features).

• Data subjects: Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Business and contractual partners. Users (e.g. website visitors, users of online services).

• Purposes of processing: Office and organisational procedures. Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Apple iCloud: Cloud storage and synchronisation service used to store app data across a user’s Apple devices (e.g. learning progress, settings). Use of the service is optional and depends on the user’s iCloud settings. Legal basis: our legitimate interests (Article 6 (1) (f) UK GDPR) in secure storage and convenient synchronisation of user data on Apple devices; Service provider: Apple Distribution International Limited, Hollyhill Industrial Estate, Hollyhill, Cork, Ireland; Website: https://www.apple.com. Privacy Policy: https://www.apple.com/legal/privacy/en-ww/.

• Google Workspace: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://workspace.google.com/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third-country transfers: United Kingdom – UK Extension to the EU–U.S. Data Privacy Framework (“UK–U.S. Data Bridge”), the International Data Transfer Agreement (IDTA) and/or the UK Addendum to the EU Standard Contractual Clauses; EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause); Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause). Further Information: https://cloud.google.com/privacy.

 

Web Analysis, Monitoring and Optimization

Web analytics (also referred to as "reach measurement") is used to evaluate the visitor flows of our online services and may include pseudonymous values related to visitor behavior, interests, or demographic information such as age or gender. Through reach analysis, we can, for example, identify when our online services or their functions and content are most frequently used or likely to encourage repeat visits. It also enables us to determine which areas need optimization.

In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online services or their components.

Unless otherwise specified below, profiles (i.e., data combined from a usage process) may be created for these purposes, and information can be stored in and later retrieved from a browser or device. The data collected includes, in particular, visited websites and elements used on them, as well as technical information such as the browser used, the computer system, and information about usage times. If users have given consent to the collection of their location data to us or to the providers of the services we use, the processing of location data is also possible.

Additionally, users' IP addresses are stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analytics, A/B testing, or optimization. Instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, only the information stored in their profiles for the respective procedures.

Legal basis information: If we ask users for their consent to use third-party providers, the legal basis for data processing is consent in accordance with Article 6 (1) (a) UK GDPR (and, where applicable, the requirements of the Privacy and Electronic Communications (EC Directive) Regulations 2003 – “PECR”). Otherwise, user data is processed based on our legitimate interests pursuant to Article 6 (1) (f) UK GDPR (i.e., our interest in efficient, economic, and user-friendly services). In this context, we would also like to point out the information on the use of cookies in this privacy policy.

• Processed data types: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract object, duration, customer category).

• Data subjects: Users (e.g. website visitors, users of online services); Service recipients and clients. Business and contractual partners.

• Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Provision of contractual services and fulfillment of contractual obligations; Conversion tracking (Measurement of the effectiveness of marketing activities); Marketing. Provision of our online services and usability.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).

• Security measures: IP Masking (Pseudonymization of the IP address).

• Legal Basis: Consent (Article 6 (1) (a) UK GDPR). Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• PostHog Cloud EU: Web analytics, reach and conversion measurement – collection of information about the use of our online service by users in terms of its functions, content and duration of use. Legal basis: Legitimate interests (Article 6 (1) (f) UK GDPR) in analysing and improving our service. Right to object: You can object to processing for analytics purposes at any time by disabling analytics in the app settings. Standard Contractual Clauses: https://posthog.com/privacy (part of the data processing agreement); Data Processing Agreement: https://posthog.com/privacy; Further information: operation on EU servers; Service provider: PostHog Inc., 261 Market St., #4008, San Francisco, CA 94114, USA; Website: https://posthog.com/. Privacy Policy: https://posthog.com/privacy.

• RevenueCat : Provision of technical and organizational infrastructure for the creation as well as administration and transaction handling of in-app purchases and subscriptions; Service provider: Revenuecat, Inc., 1032 E Brandon Blvd #3003 Brandon, Fl 33511 USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.revenuecat.com/. Privacy Policy: https://www.revenuecat.com/privacy/.

 

Management, Organization and Utilities

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

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include 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 processes, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

• Processed data types: Content data (e.g. textual or pictorial messages and contributions, as well as information pertaining to them, such as details of authorship or the time of creation.); Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and features); Meta, communication and process data (e.g. IP addresses, timestamps, identification numbers, involved parties); Inventory data (For example, the full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or phone numbers). Contract data (e.g. contract object, duration, customer category).

• Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Prospective customers. Business and contractual partners.

• Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organisational procedures. Communication.

• Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion".

• Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR).

Further information on processing methods, procedures and services used:

• Notion: Project management - organization and administration of teams, groups, workflows, projects and processes; Service provider: Notion Labs, Inc., 548 Market St #74567, San Francisco, CA 94104-5401, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://www.notion.com/de/product; Privacy Policy: https://www.notion.so/notion/Privacy-Policy-3468d120cf614d4c9014c09f6adc9091; Data Processing Agreement: Provided by the service provider. Basis for third-country transfers: United Kingdom – UK International Data Transfer Agreement (IDTA) and/or UK Addendum to the EU Standard Contractual Clauses (provided by the service provider); EEA – Standard Contractual Clauses (provided by the service provider); Switzerland – Standard Contractual Clauses (provided by the service provider).

• Slack: Messenger and conference software; Service provider: Slack Technologies Limited, Level 1, Block A Nova Atria North, Sandyford Business District, Dublin 18, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) UK GDPR); Website: https://slack.com/; Privacy Policy: https://slack.com/intl/en-de/legal; Data Processing Agreement: https://slack.com/intl/de-de/terms-of-service/data-processing. Basis for third-country transfers: United Kingdom – UK Extension to the EU–U.S. Data Privacy Framework (“UK–U.S. Data Bridge”) and/or the use of the UK Addendum to the EU Standard Contractual Clauses and/or the International Data Transfer Agreement (IDTA) (as provided by the service provider); EEA – Data Privacy Framework (DPF), Standard Contractual Clauses (https://slack.com/intl/de-de/terms-of-service/data-processing); Switzerland – Data Privacy Framework (DPF), Standard Contractual Clauses (https://slack.com/intl/de-de/terms-of-service/data-processing).

 

Changes and Updates

We kindly ask you to inform yourself regularly about the contents of our privacy policy. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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

 

Terminology and Definitions

In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

• Artificial Intelligence (AI): The purpose of processing data through Artificial Intelligence (AI) includes the automated analysis and processing of user data to identify patterns, make predictions, and improve the efficiency and quality of our services. This involves the collection, cleansing, and structuring of data, training and applying AI models, as well as the continuous review and optimisation of results, and is carried out exclusively with users' consent or based on legal authorisation grounds.

• Contact data: Contact details are essential information that enables communication with individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as means of communication like social media handles and instant messaging identifiers.

• Content data: Content data comprise information generated in the process of creating, editing, and publishing content of all types. This category of data may include texts, images, videos, audio files, and other multimedia content published across various platforms and media. Content data are not limited to the content itself but also include metadata providing information about the content, such as tags, descriptions, authorship details, and publication dates.

• Contract data: Contract data are specific details pertaining to the formalisation of an agreement between two or more parties. They document the terms under which services or products are provided, exchanged, or sold. This category of data is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may encompass the start and end dates of the contract, the nature of the agreed-upon services or products, pricing arrangements, payment terms, termination rights, extension options, and special conditions or clauses. They serve as the legal foundation for the relationship between the parties and are crucial for clarifying rights and duties, enforcing claims, and resolving disputes.

• Controller: "Controller" means 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, within the meaning of applicable data protection law (in particular the UK GDPR).

• Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).

• Employees: As employees, individuals are those who are engaged in an employment relationship, whether as staff, employees, or in similar positions. Employment refers to a legal relationship between an employer and an employee, established through an employment contract or agreement. It entails the obligation of the employer to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various stages, including establishment, where the employment contract is concluded, execution, where the employee carries out their work activities, and termination, when the employment relationship ends, whether through termination, mutual agreement, or otherwise. Employee data encompasses all information pertaining to these individuals within the context of their employment. This includes aspects such as personal identification details, identification numbers, salary and banking information, working hours, holiday entitlements, health data, and performance assessments.

• Inventory data: Inventory data encompass essential information required for the identification and management of contractual partners, user accounts, profiles, and similar assignments. These data may include, among others, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data form the foundation for any formal interaction between individuals and services, facilities, or systems, by enabling unique assignment and communication.

• Log data: Protocol data, or log data, refer to information regarding events or activities that have been logged within a system or network. These data typically include details such as timestamps, IP addresses, user actions, error messages, and other specifics about the usage or operation of a system. Protocol data is often used for analyzing system issues, monitoring security, or generating performance reports.

• Meta, communication and process data: Meta-, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, include information that describes the context, origin, and structure of other data. They can include details about file size, creation date, the author of a document, and modification histories. Communication data capture the exchange of information between users across various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the involved parties, timestamps, and transmission paths. Procedural data describe the processes and operations within systems or organisations, including workflow documentations, logs of transactions and activities, and audit logs used for tracking and verifying procedures.

• Payment Data: Payment data comprise all information necessary for processing payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account information, payment amounts, transaction dates, verification numbers, and billing information. Payment data may also contain information on payment status, chargebacks, authorizations, and fees.

• Personal Data: "personal data" means any information relating to an identified or identifiable natural person ("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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, within the meaning of applicable data protection law (in particular the UK GDPR).

• Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure, within the meaning of applicable data protection law (in particular the UK GDPR).

• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.

• Usage data: Usage data refer to information that captures how users interact with digital products, services, or platforms. These data encompass a wide range of information that demonstrates how users utilise applications, which features they prefer, how long they spend on specific pages, and through what paths they navigate an application. Usage data can also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. They are particularly valuable for analysing user behaviour, optimising user experiences, personalising content, and improving products or services. Furthermore, usage data play a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.

• Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of their websites to the needs of their visitors. For the purposes of web analytics, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.