Privacy Policy

1. General

This privacy notice explains how, to what extent and for what purposes your personal data (hereinafter referred to as ‘you’, ‘visitor’ or ‘user’) is processed on this website and by the company named below. The company referred to in section 3 (hereinafter ‘we’) is the service provider and data controller within the meaning of data protection law.

2. Name and contact details of the data controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) is

Pelka und Sozien GmbH

Law Firm and Tax Consultancy

Kaiser-Wilhelm-Ring 3 – 5

50672 Cologne

Telephone: +49 221 54678 0

Fax: +49 221 54402 8

Email: koeln@pelkapartner.de

3. Contact details of the company data protection officer

The company data protection officer can be contacted as follows:

Pelka und Sozien GmbH

Law firm

Tax consultancy

Kaiser-Wilhelm-Ring 3 – 5

50672 Cologne

Telephone: +49 221 54678 0

Fax: +49 221 54402 8

Email: datenschutzbeauftragter@pelkapartner.de

4. Collection and storage of personal data, and the scope and purpose of processing

a) Data storage when accessing the website

When you access our website www.pelkapartner.de, the browser used on your device automatically sends information to our website’s server. We store this information temporarily in a so-called log file and it is automatically anonymised or deleted 7 days after you have finished visiting our website. The log files contain IP addresses or other data that enable a visitor to be identified. The following information is collected without any action on your part and stored until it is automatically deleted:

• IP address of the requesting computer,
• date and time of access,
• name and URL of the file accessed,
• website from which access took place (referrer URL),
• the browser used,
• where applicable, your computer’s operating system,
• the name of your internet service provider,
• the status and the volume of data transferred during your visit to our website.

We process the aforementioned data for the following purposes:

• to ensure the website connects smoothly,
• to ensure a user-friendly experience on our website,
• to evaluate system security and stability, and
• to facilitate and improve the administration of the website.

The legal basis for this data processing is Article 6(1)(f) of the GDPR. Our legitimate interest arises from the purposes of data collection listed above, in particular to ensure the functionality of the website. The processing is expressly not carried out for the purpose of gaining insights into the identity of the website visitor.

When you visit our website, we use cookies and analytics services. Further details on the use of cookies and analytics services can be found in sections 6 and 9 of this privacy notice.

b) Data storage when subscribing to our newsletter

By subscribing to the newsletter, the visitor expressly consents to the processing of the personal data provided. A reference to this privacy notice is provided.

The legal basis for processing the visitor’s personal data for the purpose of sending newsletters is consent in accordance with Article 6(1)(a) of the GDPR.

We use your email address to send you our newsletter on a regular basis and to promote our firm’s services, such as (paid) webinars.

To receive the newsletter, you only need to provide an email address (mandatory field).

The user’s email address will be stored for as long as the newsletter subscription remains active.

You may unsubscribe at any time. You can unsubscribe either via a link at the end of each newsletter or at any time by emailing redaktion@pelkapartner.de.

c) Data storage when using our contact form

If you have any questions, you can contact us via a form provided on the website. You must provide a valid email address as well as your first name and surname so that we know who the enquiry is from and can respond to it. Further details may be provided on a voluntary basis.

By submitting the message via the contact form, the visitor consents to the processing of the personal data provided. A reference to this privacy notice is provided. Data processing is carried out solely for the purpose of handling and responding to enquiries via the contact form. This is done on the basis of consent given voluntarily in accordance with Article 6(1)(a) of the GDPR. The personal data collected for the use of the contact form is automatically deleted as soon as the enquiry has been dealt with and there are no grounds for further retention (e.g. subsequent engagement of our law firm). The user may withdraw their consent to the processing of personal data at any time.

d) Data storage in connection with the sending of an email

The legal basis for the processing of data transmitted in connection with the sending of an email is Article 6(1)(f) of the GDPR. The personal data sent by email will be deleted once the relevant conversation with the user has ended. The conversation is deemed to have ended when it is clear from the circumstances that the matter in question has been conclusively resolved. If the user contacts us by email, they may object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. In this case, all personal data stored in the course of the contact will be deleted.

e) Data storage in connection with enquiries made by telephone or fax

If you contact us by telephone or fax, your enquiry, including all personal data contained therein (name, enquiry), will be stored and processed by us for the purpose of dealing with your request. We will not pass on this data without your consent. The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your enquiry relates to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR), provided that this has been requested.

The data you provide to us via a contact enquiry will be retained by us until you request its deletion, withdraw your consent to its storage, or the purpose for storing the data no longer applies (e.g. once your enquiry has been fully processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.

5. Disclosure of data

We will only disclose your personal data if

• you have given your explicit consent in accordance with Article 6(1)(a) of the GDPR,
• or if disclosure is necessary in accordance with Article 6(1)(f) of the GDPR
• • for the establishment,
  • exercise or
  • defence

legal claims, and there is no reason to assume that you have an overriding legitimate interest in preventing the disclosure of your data,

• there is a legal obligation to disclose the data pursuant to Article 6(1)(c) of the GDPR,
• or this is necessary pursuant to Article 6(1)(b) of the GDPR for the performance of contractual relationships with you.

Note on data transfers to the USA and other third countries

Among other things, we use tools provided by companies based in the USA or other third countries that do not offer a level of data protection comparable to that of the EU. When these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to disclose personal data to security authorities without you, as the data subject, being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g. intelligence services) may process, analyse and permanently store your data held on US servers for surveillance purposes. We have no influence over these processing activities.

6. Cookies

The website uses so-called cookies. These are data packets that are exchanged between the law firm’s website server and the visitor’s browser and are stored on the devices used (PC, laptop, tablet, smartphone, etc.) when visiting the website. Cookies cannot, in this respect, cause any damage to the devices used. In particular, they do not contain any viruses or other malware. Information is stored in the cookies that relates to the specific device being used. We cannot, under any circumstances, thereby gain direct knowledge of the identity of the website visitor.

Your browser settings can be configured so that cookies are either not accepted on the devices used, or so that a specific notification is displayed before a new cookie is created. Please note, however, that disabling cookies may mean that not all functions of the website can be used to their full potential.

The use of cookies serves to make our website more convenient and user-friendly. For example, our own session cookies can be used to determine whether a visitor has already visited specific pages on the website. These session cookies are automatically deleted once you leave the website.

To improve user-friendliness, our own temporary cookies may be used where necessary. These are stored on the visitor’s device for a temporary period of up to 3 days. If the visitor returns to the website within this time, the system automatically recognises that the visitor has previously accessed the site and recalls any entries and settings made during that visit, so that these do not need to be repeated.

In addition, subject to your prior consent, analytics cookies may be used to analyse website traffic for statistical purposes and to improve the service. These cookies enable the system to automatically recognise, upon a subsequent visit, that the visitor has previously accessed the website. These cookies are automatically deleted after a specified period of time.

The legal basis for the use of necessary cookies for the above-mentioned purposes is Article 6(1)(f) of the GDPR. There is a legitimate interest in providing and optimising a functional and user-friendly online service. The use of non-technically necessary cookies for analytical purposes takes place only with the prior consent of the website visitor, on the basis of Article 6(1)(a) of the GDPR.

7. Your rights as a data subject

As a ‘data subject’ within the meaning of the GDPR, whose personal data is processed by us, you are entitled to the following rights:

7.1 Right of access

You may request information from us as to whether personal data concerning you is being processed by us. There is no right of access if the provision of the requested information would breach the duty of confidentiality pursuant to Section 57(1) and Section 62 of the Tax Advisers Act (StBerG), § 43a of the Federal Lawyers’ Act (BRAO) and § 43(1), first sentence, and § 50 of the Westphalian Lawyers’ Act (WPO), or if the information must be kept confidential for other reasons, in particular due to an overriding legitimate interest of a third party. Notwithstanding this, an obligation to provide the information may exist if, in particular having regard to the risk of imminent harm, your interests outweigh the interest in confidentiality. Furthermore, the right to information is excluded if the data is stored solely because it may not be deleted due to statutory or statutory retention periods, or serves exclusively the purposes of data backup or data protection monitoring, provided that providing the information would require a disproportionately high level of effort and processing for other purposes is prevented by appropriate technical and organisational measures. Provided that, in your case, the right to access information is not excluded and we are processing your personal data, you may request the following information from us:

• the purposes of the processing,
• the categories of personal data relating to you that are being processed,
• the recipients or categories of recipients to whom your personal data is disclosed, in particular where recipients are in third countries,
• where possible, the envisaged period for which your personal data will be stored or, if this is not possible, the criteria used to determine the storage period,
• the existence of a right to rectification or erasure or restriction of processing of the personal data concerning you, or a right to object to such processing,
• the existence of a right to lodge a complaint with a supervisory authority,
• where the personal data have not been collected from you as the data subject, the available information regarding the origin of the data,
• where applicable, the existence of automated decision-making, including profiling, and, where applicable, meaningful information about the logic involved, as well as the significance and intended consequences of automated decision-making,
• where applicable, in the event of transfer to recipients in third countries, provided there is no decision by the European Commission on the adequacy of the level of protection pursuant to Article 45 of the GDPR, information on the appropriate safeguards provided for in accordance with Article 46 of the GDPR to protect the personal data.

7.2 Rectification and Completion

If the personal data concerning you is inaccurate, you may request that we rectify such inaccurate data without delay. If the personal data concerning you is incomplete, you may request that it be completed.

7.3 Erasure

You have the right to have your data erased (‘right to be forgotten’), provided that the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for the performance of a task carried out in the public interest, for reasons of public interest in the area of public health, for archiving purposes, or for the establishment, exercise or defence of legal claims, and one of the following grounds applies:

• The personal data is no longer necessary for the purposes for which it was processed,
• The legal basis for the processing was solely your consent, which you have withdrawn,
• You have objected to the processing of your personal data that we have made public,
• you have objected to the processing of personal data that we have not made public, and there are no overriding legitimate grounds for the processing,
• Your personal data has been processed unlawfully,
• The erasure of the personal data is necessary to comply with a legal obligation to which we are subject.
• The personal data was collected in connection with information society services offered in accordance with Article 8(1).

There is no right to erasure if, in the case of lawful, non-automated data processing, erasure is not possible or is only possible with disproportionately high effort due to the specific nature of the storage, and your interest in erasure is minimal. In this case, restriction of processing shall take the place of erasure.

7.4 Restriction of processing

You may request that we restrict the processing of your data if any of the following grounds apply:

• You contest the accuracy of the personal data.
• In this case, restriction may be requested for the period necessary to enable us to verify the accuracy of the data;
• the processing is unlawful and you request restriction of the use of your personal data instead of erasure;
• we no longer require your personal data for the purposes of processing. However, you require it to establish, exercise or defend legal claims;
• you have objected to the processing in accordance with Article 21(1) of the GDPR. Restriction of processing may be requested until it has been determined whether our legitimate grounds override your grounds.

7.5 Data portability

You have a right to data portability provided that the processing is based on your consent (Article 6(1)(a) or Article 9(2)(a) of the GDPR) or on a contract to which you are a party in accordance with Article 6(1)(b) of the GDPR, and the processing is carried out by automated means. In this case, the right to data portability encompasses the following rights, provided that this does not infringe upon the rights and freedoms of other individuals:

You may request that we provide you with the personal data you have supplied to us in a structured, commonly used and machine-readable format. You have the right to transmit this data to another controller without hindrance from us. Where technically feasible, you may request that we transmit your personal data directly to another controller.

7.6 Objection

Where processing is based on Article 6(1)(f) of the GDPR, you have the right to object at any time to the processing of personal data concerning you on grounds relating to your particular situation. This also applies to profiling based on Article 6(1)(f) of the GDPR. Once you have exercised your right to object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to establish, exercise or defend legal claims.

Where the processing of your personal data is carried out for the purposes of direct marketing, you may object at any time. This also applies to profiling associated with such direct marketing. Once you have exercised this right to object, we will no longer use the personal data in question for the purposes of direct marketing.

You may notify us of your objection informally by email, telephone, fax or post using the contact details for our law firm set out at the beginning of this privacy notice.

7.7 Withdrawal of consent

You have the right to withdraw any consent you have given at any time with effect for the future. You may notify us of the withdrawal of your consent informally by email, telephone, fax or post using the contact details for our law firm listed at the beginning of this privacy notice.

Withdrawal does not affect the lawfulness of data processing carried out on the basis of your consent up to the point of receipt of the withdrawal. Upon receipt of the withdrawal, any data processing that was based solely on your consent will cease.

7.8 Complaints

If you believe that the processing of your personal data infringes the GDPR, you may lodge a complaint with a data protection supervisory authority responsible for your place of residence or work, or for the place where the alleged infringement occurred.

8. Data Protection in Relation to Job Applications and the Recruitment Process

The data controller collects and processes applicants’ personal data for the purpose of conducting the recruitment process on the basis of Article 6(1)(b) and (f) of the GDPR. Processing may also take place electronically. This is particularly the case where an applicant submits the relevant application documents to the data controller electronically, for example by email or via a web form on the website. If the data controller enters into an employment contract with an applicant, the data submitted will be stored and processed for the purpose of managing the employment relationship in accordance with the relevant legal provisions. If the data controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after the decision has been communicated, provided that no other legitimate interests of the data controller preclude such deletion. An example of such a legitimate interest in this context is the burden of proof in proceedings under the General Equal Treatment Act (AGG).

9. Analytics tools

Tracking tools

We endeavour to ensure that our website is designed to meet your needs and is continuously optimised. On the basis of Article 6(1)(a) of the GDPR, we therefore use the tracking measures listed below, subject to your prior consent. We also use these tracking measures to collect statistical data on the use of our website and to analyse this data for the purpose of optimising our offering for you. The respective data processing purposes and data categories can be found in the relevant tracking tools.

Google Analytics

Provided you have given your consent, Google Analytics 4, a web analytics service provided by Google LLC, is used on this website in accordance with Article 6(1)(a) of the GDPR. The data controller for users in the EU, the EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (‘Google’).

Nature, purpose and scope of processing

Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected via the cookies regarding your use of this website is generally transmitted to a Google server in the USA and stored there.

In Google Analytics 4, IP address anonymisation is enabled by default.

Due to IP anonymisation, your IP address is truncated by Google within Member States of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there. According to Google, the IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google. During your visit to the website, your user behaviour is recorded in the form of ‘events’. Events may include:

• Page views
• First visit to the website
• Start of the session
• Your ‘click path’, interaction with the website
• Scrolls (whenever a user scrolls to the bottom of the page (90%))
• Clicks on external links
• Internal search queries
• Interaction with videos
• File downloads
• Ads viewed / clicked
• Language setting

The following is also recorded:

• Your approximate location (region)
• Your IP address (in truncated form)
• Technical information about your browser and the devices you use (e.g. language setting, screen resolution)
• Your internet service provider
• the referrer URL (the website or advertising material via which you arrived at this website)

Purposes of processing

On behalf of the operator of this website, Google will use this information to analyse your pseudonymous use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyse the performance of our website and the success of our marketing campaigns.

Recipients

Recipients of the data are/may be

• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (as a data processor under Article 28 of the GDPR)
• Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
• Alphabet Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

It cannot be ruled out that US authorities may access the data stored by Google.

Transfers to third countries

Where data is processed outside the EU or the EEA and there is no level of data protection equivalent to European standards, we have entered into EU Standard Contractual Clauses with the service provider to ensure an adequate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. The transfer of data to the USA and access by US authorities to data stored by Google cannot be ruled out. From a data protection perspective, the USA is currently regarded as a third country. You do not have the same rights there as you do within the EU or the EEA. You may not have any legal remedies against access by authorities to

Retention period

The data we send that is linked to cookies is automatically deleted after 3 months. Data for which the retention period has expired is automatically deleted once a month.

Legal basis

The legal basis for this data processing is your consent in accordance with Article 6(1)(a) of the GDPR.

Withdrawal

You may withdraw your consent at any time with future effect by accessing the cookie settings and changing your selection there.

The lawfulness of the processing carried out on the basis of your consent up until its withdrawal remains unaffected.

You can also prevent cookies from being stored in the first place by adjusting your browser settings accordingly. However, if you configure your browser to reject all cookies, this may result in restricted functionality on this and other websites. Furthermore, you can prevent the collection of data generated by the cookie and relating to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by

• not giving your consent to the setting of the cookie, or
• downloading and installing the browser add-on to deactivate Google Analytics HERE.

Further information on the terms of use of Google Analytics and Google’s privacy policy can be found at https://marketingplatform.google.com/about/analytics/terms/de/ and at https://policies.google.com/?hl=de.

10. Plug-ins

LinkedIn

We use social plug-ins from the social network LinkedIn on our website on the basis of Article 6(1)(a) of the GDPR. This serves to raise awareness of our law firm, and the underlying promotional purpose is to be regarded as a legitimate interest within the meaning of the GDPR. Responsibility for ensuring that these plug-ins are operated in compliance with data protection regulations lies with their respective providers. We integrate these plug-ins using the so-called ‘two-click method’, whereby data is only processed once the visitor has given their consent, in order to provide the best possible protection for visitors to our website. Consent may be withdrawn at any time with effect for the future.

11. Use of web fonts

External fonts from Google Fonts may be used on our website. Google Fonts is a service provided by Google Inc. (‘Google’). These fonts are integrated via a server request, usually to a Google server. This results in information being transmitted to the server regarding which pages of our website you have visited. Google also stores the IP address of the browser on the visitor’s device.

The use of Google Web Fonts is in the interests of ensuring a consistent and attractive presentation of our online content. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the GDPR.

If your browser does not support Web Fonts, a standard font from your computer will be used.

Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de&gl=de.

12. Audio and video conferences

Data processing

We use online conferencing tools, amongst other means, to communicate with our clients. The specific tools we use are listed below. When you communicate with us via video or audio conference over the internet, your personal data is collected and processed by us and by the provider of the relevant conferencing tool.

The conferencing tools collect all data that you provide or use in order to utilise the tools (email address and/or your telephone number). Furthermore, the conferencing tools process information regarding the duration of the conference, the start and end times of your participation in the conference, the number of participants and other ‘contextual information’ relating to the communication process (metadata).

Furthermore, the tool provider processes all technical data required to facilitate online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speakers, and the type of connection.

Where content is exchanged, uploaded or otherwise made available within the tool, this is also stored on the tool providers’ servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared whilst using the service.

Please note that we do not have full control over the data processing operations carried out by the tools used. Our options are largely determined by the corporate policy of the respective provider. Further information on data processing by the conferencing tools can be found in the privacy policies of the respective tools, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to provide specific services to our customers (Article 6(1)(b) of the GDPR). Furthermore, the use of these tools serves to generally simplify and speed up communication with us or our company (legitimate interest within the meaning of Article 6(1)(f) of the GDPR). Where consent has been sought, the use of the relevant tools is based on this consent in accordance with Article 6(1)(a) of the GDPR; consent may be withdrawn at any time with effect for the future.

Retention period

Data collected directly by us via the video and conferencing tools will be deleted from our systems as soon as you request us to do so, withdraw your consent to storage, or the purpose for storing the data no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected. We have no influence over the retention period of your data stored by the operators of the conferencing tools for their own purposes. For further details, please contact the operators of the conferencing tools directly.

Conferencing tools used

We use the following conference tools:

GoToMeeting

We use GoToMeeting. The provider is LogMeIn, Inc., 333 Summer Street, Boston, MA 02210, USA. For details on data processing, please refer to GoToMeeting’s privacy policy: https://www.logmeininc.com/de/legal/privacy.

Data transfers to the USA are based on the EU Commission’s Standard Contractual Clauses. Further details can be found here: https://logmeincdn.azureedge.net/legal/lmi-customer-dpa-2020v1-de.pdf.

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

For details on data processing, please refer to Microsoft’s privacy policy: https://www.microsoft.com/de-de/privacy/privacystatement.

Swyx Meeting

We use Swyx Meeting. The provider is Enreach Germany GmbH, Robert-Bosch-Straße 1, 44803 Bochum, Germany. For details on data processing, please refer to Enreach Germany GmbH’s privacy policy: https://enreach.de/de/datenschutz.

Data Processing

We have entered into a data processing agreement (DPA) with the aforementioned providers. This is a contract required under data protection law, which ensures that the data processor processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

13. Hosting

Vercel

We host our website with Vercel. The provider is Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA (hereinafter “Vercel”).

When you visit our website, Vercel processes technically necessary connection and usage data. This may include, in particular, your IP address, device and browser information, as well as technical log and telemetry data. The processing of this data is necessary to provide our website and to ensure its security, stability and performance.

Further information on data processing by Vercel can be found in Vercel’s privacy policy:

https://vercel.com/legal/privacy-notice

The use of Vercel is based on Article 6(1)(f) of the GDPR. We have a legitimate interest in the secure, reliable and high-performance provision of our website.

Where consent is sought in connection with the operation of our website, the relevant processing is carried out on the basis of Article 6(1)(a) of the GDPR and, where applicable, Section 25(1) of the TDDDG. Consent may be withdrawn at any time with future effect.

Data transfer to the USA

Vercel is a company based in the USA. The processing of personal data in the USA or other countries outside the European Union or the European Economic Area cannot therefore be ruled out.

Vercel is certified under the EU-US Data Privacy Framework. Furthermore, Vercel’s Data Processing Addendum provides for the use of the Standard Contractual Clauses approved by the European Commission for such data transfers.

Where technically feasible, we use the Vercel region in Frankfurt am Main (fra1) to host our website. However, the processing of personal data outside the European Union, particularly in the USA, cannot be completely ruled out.

Data processing on behalf of a controller

We have entered into a data processing agreement with Vercel in accordance with Article 28 of the GDPR. This contract ensures that Vercel processes the personal data of our website visitors only in accordance with our instructions and in compliance with the applicable data protection regulations.

14. Data security

Please note that the transfer of data over the internet is not entirely secure. We cannot therefore guarantee absolute security for the transmission of information to us via the internet.

Where possible, we use the widely adopted TLS (Transport Layer Security) protocol in conjunction with the highest level of encryption supported by your browser when you visit our website. This is usually 256-bit encryption. If your browser does not support 256-bit encryption, we will use 128-bit technology instead. You can tell whether a particular page on our website is being transmitted in encrypted form by the closed appearance of the key or padlock icon in the status bar at the bottom of your browser.

We implement appropriate technical and organisational security measures to protect your data against accidental or deliberate manipulation, partial or complete loss, destruction or unauthorised access by third parties, insofar as this is within our power. Our security measures are continuously improved in line with technological developments.

15. Validity and amendments to this privacy policy

We are constantly developing our website and the services we offer. In particular, when new technologies are implemented and used, it may become necessary to amend this privacy policy. The same applies in the event of changes to legislation or regulatory requirements. We therefore recommend that you read this privacy policy carefully not only now, but also from time to time.

This privacy policy is current as of August 2026.