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Data Protection

Table of Contents

Introduction

With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

Responsible persons

Michal Zuczek
Office Director

Time Change s.r.o
Karolinska 654/2
Prague 8 – Karlin
186 00, Czech Republic

+420 776 013 600
prague@time-change.com

Overview of processing

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

Inventory data
Payment data
Contact details
Content data
Contract data
Usage data
Meta/communication data
Event dates (Facebook)

Customers
Interested parties
Communication partner
Users
Business and contractual partners

Provision of contractual services and customer service
Contact requests and communication
Direct marketing
Reach measurement
Tracking
Office and organizational procedures
Conversion measurement
Managing and responding to inquiries
Feedback
Marketing
Profiles with user-related information
Provision of our online services and user-friendliness
Information technology infrastructure

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) 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.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. State data protection laws of the individual federal states may also apply.

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. We also take the protection of personal data into account as early as the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.
TLS encryption (https): We use TLS encryption to protect your data transmitted via our online offering. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

As part of our processing of personal data, data may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

Tools from companies based in the USA are integrated on this website. By activating the tools, your personal data may be forwarded to the US servers of the respective company. The USA is not a safe third country within the meaning of EU data protection law. US companies are obliged to hand over personal data to security authorities without the data subject being able to take legal action against this. It cannot be ruled out that US authorities may process, permanently store or analyze your data located on US servers for monitoring purposes. We have no influence on these processing activities.

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other permissions no longer apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person.
Our data protection notices may also contain further information on the storage and deletion of data, which apply primarily to the respective processing.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to analyze visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offer). The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for their consent. If users give their consent, the legal basis for processing their data is the consent given. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.general information on revocation and objection (opt-out): Users can withdraw the consent they have given at any time and also object to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. Further information on processing operations, procedures and services:
  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used. If we store non-required cookies on your device, the legal basis is your consent in accordance with Section 25 TDDDG.

We use analytics cookies to collect information about how users navigate and use our websites. These cookies help us improve the performance of our pages and make them more user-friendly. Some of these are persistent cookies, which remain stored on your computer or another internet-connected device for a certain period after your browsing session ends, unless you delete them. These cookies are provided by third parties for analytics purposes, including Google Analytics.

In certain cases, we collaborate with third parties to offer specific services to our users, such as additional features (including the ability to watch videos on our websites) and to connect with specific social networks. These third parties use cookies to collect information on our websites, including through plugins and widgets.

The privacy practices of these third parties—including Facebook, Instagram, LinkedIn, and Google—are subject to their own privacy policies, which are available here: Facebook, Instagram, LinkedIn, Google.

Preference for Third-Party Cookies
I accept third-party cookies.

Your Choices
You can prevent cookies from being downloaded to your computer by adjusting the appropriate settings in your web browser. You can find out how to do this for your specific browser by clicking on “Help” in your browser menu or by visiting www.allaboutcookies.org.

Please note, however, that without cookies you may not be able to take full advantage of the websites or our products and services.

Contact us if you have any questions about this cookie policy.

We use Google Analytics from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as an analysis service for the statistical evaluation of our online offering. This analysis includes, for example, the number of visits to our website, sub-pages visited and the time spent by visitors. Google Analytics uses cookies and other browser technologies to evaluate user behaviour and recognize users. This information is used, among other things, to compile reports on the activity of the website and thus to continuously develop it further. We use Google Analytics with the addition “anonymize_ip” so that your IP address is shortened by Google.
We process data with the help of Google Analytics for the purpose of optimizing our website and for marketing purposes on the basis of your consent pursuant to Art. 6 para. 1 sentence 1 lit. a). GDPR. You can revoke your consent at any time via the settings in the cookie consent banner.
The data collected through the use of Google Analytics may also be transferred to so-called insecure third countries, in particular to the USA. For these cases, we have concluded an order processing contract with Google Limited including standard contractual clauses in order to legitimize the data transfer in accordance with Art. 46 para. 2 lit. c) GDPR. In addition, we ensure that your data is adequately protected by shortening your IP address.
Further information on data processing at Google can be found here!

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), 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 updating obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and efficient business management as well as in security measures to protect our contractual partners and our business operations from misuse, threats to 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 pass on 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 other forms of processing, e.g. for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for trading books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for commercial and business letters received and reproductions of commercial and business letters sent. 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, the record was made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

  • Processed data types: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Interested parties; business and contractual partners; customers.
  • Purposes of Processing: Provision of contractual services and customer support; contact requests and communication; Office and organizational procedures; Managing and responding to inquiries; Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles).
  • Legal bases: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests, such as the provision of contractual services (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

  • Economic Analyses and Market Research:
    For economic reasons and in order to recognize market trends and the preferences of contractual partners and users, we analyze the data available to us concerning business transactions, contracts, inquiries, etc. The group of data subjects may include contractual partners, interested parties, customers, visitors, and users of our online services.
    These analyses are carried out for business evaluations, marketing purposes, and market research (e.g. to identify customer groups with differing characteristics). If available, we may also consider the profiles of registered users, including details such as services used.
    The analyses are for our internal use only and are not disclosed externally, unless they are anonymous analyses with aggregated (i.e. anonymized) values.
    Furthermore, we respect users’ privacy and process the data for analytical purposes in a pseudonymized and, where possible, anonymized form (e.g. as aggregated data).
    Legal basis: Legitimate interests, such as business optimization (Art. 6 para. 1 sentence 1 lit. f) GDPR)
  • Agency Services:
    We process our customers’ data in the course of providing our contractual services, which may include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting, and training services.
    Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)
  • Project and Development Services:
    We process the data of our customers and clients (hereinafter collectively referred to as “customers”) in order to enable them to select, purchase, or commission the chosen services or works and related activities, as well as to facilitate payment, provision, and delivery or performance.
    The required information is identified as such during the ordering, commissioning, or comparable contractual process and includes the information necessary for service provision and billing, as well as contact details for potential follow-up queries.
    If we gain access to information about end users, employees, or other individuals, we process such data in accordance with legal and contractual requirements.
    Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)
  • Events and Activities:
    We process the data of participants in the events, activities, and similar gatherings that we organize or host (hereinafter collectively referred to as “participants” and “events”) in order to enable their participation and the use of services or features associated with participation.
    If we process health-related data, religious or political beliefs, or other special categories of personal data in this context, it is done based on the principle of obviousness (e.g. thematically focused events), for health or safety reasons, or with the explicit consent of the data subjects.
    The required information is identified as such during the ordering, registration, or comparable contractual process and includes the information necessary for service provision and billing, as well as contact details for any necessary communication.
    If we gain access to information about end customers, employees, or other individuals, we process it in accordance with legal and contractual obligations.
    Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)

Provision of the online offer and web hosting

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

Types of Data Processed:
Usage data (e.g. visited websites, interest in content, access times);
Meta/communication data (e.g. device information, IP addresses);
Content data (e.g. entries in online forms).

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

Purposes of Processing:

  • Provision of our online offering and user-friendliness

  • Information technology infrastructure (operation and provision of information systems and technical equipment such as computers, servers, etc.)

  • Fulfillment of contractual obligations and customer service

Legal Basis:
Legitimate interests, such as the digital outsourcing of business operations (Art. 6 para. 1 sentence 1 lit. f) GDPR)

Further Information on Processing Operations, Procedures, and Services:

Email Transmission and Hosting:
The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of recipients and senders, as well as other information related to email transmission (e.g. the providers involved), and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of spam detection.

Please note that emails are generally not encrypted when transmitted over the internet. While emails are typically encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless so-called end-to-end encryption is used). Therefore, we cannot take responsibility for the transmission path of emails between the sender and our server.

Legal Basis:
Legitimate interests, such as enabling email communication (Art. 6 para. 1 sentence 1 lit. f) GDPR)

IONOS by 1&1:
Services in the field of providing IT infrastructure and related services (e.g. storage space and/or computing capacities)
Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany
Legal Basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Website: https://www.ionos.de
Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy
Data Processing Agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/

Contact and inquiry management

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

Types of Data Processed:
Contact data (e.g. email addresses, phone numbers);
Content data (e.g. entries in online forms);
Usage data (e.g. visited websites, interest in content, access times);
Meta/communication data (e.g. device information, IP addresses).

Data Subjects:
Communication partners.

Purposes of Processing:

  • Handling contact requests and communication

  • Administration and response to inquiries

  • Feedback (e.g. collecting feedback via online form)

  • Provision of our online offering and user-friendliness

Legal Bases:

  • Legitimate interests, such as initiating contact via electronic means (Art. 6 para. 1 sentence 1 lit. f) GDPR)

  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)

Further Information on Processing Operations, Procedures, and Services:

Contact Form:
When users contact us via our contact form, email, or other means of communication, we process the data they provide to handle their inquiry.
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legitimate interests, such as initiating contact via electronic means (Art. 6 para. 1 sentence 1 lit. f) GDPR)

HubSpot:
Customer relationship management, as well as support for sales and business processes through personalized customer care and multi-channel communication—i.e. managing customer inquiries from various channels, including analytics and feedback features.
Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA
Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Website: https://www.hubspot.de
Privacy Policy: https://legal.hubspot.com/de/privacy-policy
Data Processing Agreement: https://legal.hubspot.com/dpa
Standard Contractual Clauses (ensuring an adequate level of data protection for processing in third countries): https://legal.hubspot.com/dpa

Newsletter and electronic notifications

Newsletter and Electronic Communications:
We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described during the sign-up process, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and about us.

To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask for your name—for the purpose of personalizing the newsletter—or for additional information, if necessary for the purpose of the newsletter.

Double Opt-In Procedure:
Subscription to our newsletter is carried out using a so-called double opt-in procedure. This means that after signing up, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that no one can register using someone else’s email address.
Newsletter registrations are logged in order to be able to demonstrate the subscription process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored with the email service provider are also logged.

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

The logging of the subscription process is based on our legitimate interests in demonstrating the proper execution of the process. If we engage a service provider to send emails, this is done on the basis of our legitimate interests in using an efficient and secure mailing system.

Processed Data Types: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers); meta/communication data (e.g., device information, IP addresses); usage data (e.g., visited websites, interest in content, access times).
Affected Persons: Communication partners.
Purposes of Processing: Direct marketing (e.g., via email or postal mail).
Legal Basis: Consent (Art. 6(1)(a) GDPR); legitimate interests, expansion of direct marketing, and customer retention (Art. 6(1)(f) GDPR).
Opt-Out Option: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. A link to unsubscribe from the newsletter is provided at the end of each newsletter, or you can use one of the contact options listed above, preferably email, for this purpose.

Further Information on Processing Operations, Procedures, and Services:
HubSpot: Email marketing platform; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hubspot.de; Privacy Policy: https://legal.hubspot.com/de/privacy-policy; Data Processing Agreement: https://legal.hubspot.com/dpa; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://legal.hubspot.com/dpa.

We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as email, telephone, mail, or fax, in accordance with legal requirements.
Recipients have the right to revoke their consent at any time or to object to promotional communication at any time.
After revocation or objection, we store the data necessary to prove prior authorization for contact or communication for up to three years after the end of the year of revocation or objection, based on our legitimate interests. The processing of this data is limited to the purpose of potentially defending against claims. Based on the legitimate interest of permanently complying with the user’s revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, phone number, or name).

Processed Data Types: Inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers).
Affected Persons: Communication partners.
Purposes of Processing: Direct marketing (e.g., via email or postal mail).
Legal Basis: Consent (Art. 6(1)(a) GDPR); legitimate interests, enabling advertising on various communication channels (Art. 6(1)(f) GDPR).

Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the visitor flows to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymized values. With the help of reach analysis, we can, for example, identify when our online offering, its functions, or content are most frequently used or encourage repeat visits. We can also determine which areas require optimization.

In addition to web analytics, we may use testing procedures, for example, to test and optimize different versions of our online offering or its components.

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

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization, but rather pseudonyms. 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 purposes of the respective processes.

Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
Affected Persons: Users (e.g., website visitors, users of online services).
Purposes of Processing: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest/behavior-based profiling, use of cookies); provision of our online offering and user-friendliness.
Security Measures: IP masking (pseudonymization of the IP address).
Legal Basis: Consent (Art. 6(1)(a) GDPR). The right to withdraw consent exists (Art. 7(3) GDPR).

Further Information on Processing Operations, Procedures, and Services:
Google Analytics: Web analytics, reach measurement, and measurement of user flows; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Data Processing Agreement: https://business.safety.google/adsprocessorterms; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-Out Option: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Additional Information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

Online Marketing

We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising spaces or the display of promotional and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, through which information relevant to the display of the aforementioned content is stored about the user. This information may include, for example, viewed content, visited websites, used online networks, as well as communication partners and technical details, such as the browser used, the computer system, and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP-masking procedures (i.e., pseudonymization by truncating the IP address) to protect users. Generally, in the context of online marketing procedures, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or through similar procedures. These cookies can generally be read later on other websites that use the same online marketing procedure, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing procedure provider.
In exceptional cases, clear data may be linked to the profiles. This is the case, for example, when users are members of a social network whose online marketing procedure we use, and the network links the users’ profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, for example, by giving consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, through so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract conclusion with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that the cookies used are stored for a period of two years.

**Processed Data Types:** Usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
**Affected Persons:** Users (e.g., website visitors, users of online services).
**Purposes of Processing:** Reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavior-based profiling, use of cookies); marketing; profiles with user-related information (creation of user profiles); conversion measurement (measuring the effectiveness of marketing measures).
**Security Measures:** IP masking (pseudonymization of the IP address).
**Legal Basis:** Consent (Art. 6(1)(a) GDPR).
**Opt-Out Option:** We refer to the privacy notices of the respective providers and the opt-out options provided for them (so-called “opt-out”). If no explicit opt-out option is specified, you can disable cookies in your browser settings, though this may limit the functionality of our online offering. We therefore recommend the following opt-out options, which are collectively offered for specific regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.

**Further Information on Processing Operations, Procedures, and Services:**
**Google Ads and Conversion Measurement:** We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g., in search results, videos, on websites, etc.) to be displayed to users who have a presumed interest in the ads (so-called “conversion”). We also measure the conversion of the ads. However, we only receive the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a so-called “conversion tracking tag.” We do not receive any information that can identify users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Additional Information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

**Google AdSense with Personalized Ads:** We use the Google AdSense service with personalized ads, through which ads are displayed within our online offering, and we receive compensation for their display or other use; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Additional Information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on services, data processing terms between controllers, and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.

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

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context to communicate with users active there or to provide information about us.
We point out that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, complicate the enforcement of their rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For instance, usage profiles can be created based on user behavior and the resulting interests. These usage profiles can, in turn, be used to place advertisements within and outside the networks that presumably align with the users’ interests. For these purposes, cookies are typically stored on the users’ devices, in which their usage behavior and interests are recorded. Additionally, data independent of the devices used by users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in).
For a detailed description of the respective processing methods and opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we note that these can be most effectively exercised with the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. Should you still need assistance, you can contact us.

**Processed Data Types:** Contact data (e.g., email, phone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
**Affected Persons:** Users (e.g., website visitors, users of online services).
**Purposes of Processing:** Contact requests and communication; feedback (e.g., collecting feedback via online forms); marketing.
**Legal Basis:** Legitimate interests, enabling business expansion on social media (Art. 6(1)(f) GDPR).

**Further Information on Processing Operations, Procedures, and Services:**
**Instagram:** Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.

**Facebook Pages:** Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights,” for page operators to gain insights into how people interact with their pages and associated content. We have entered into a specific agreement with Facebook (“Information on Page Insights,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, in particular, the security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Additional Information: Joint Controller Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, particularly regarding the transfer of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).

**LinkedIn:** Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://legal.linkedin.com/dpa; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-Out Option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is thus necessary for the display of this content or functions. We strive to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Through these “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, visit times, and additional details about the use of our online offering, as well as being linked to such information from other sources.

**Processed Data Types:** Usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses); event data (Facebook) (“Event data” refers to data that can be transmitted from us to Facebook, e.g., via Facebook Pixel (through apps or other means), relating to individuals or their actions; this includes, e.g., information about website visits, interactions with content, functions, app installations, product purchases, etc.; event data is processed to create target audiences for content and advertising information (Custom Audiences); event data does not include actual content (e.g., written comments), login information, or contact details (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target audiences created from them are deleted upon deletion of our Facebook account).
**Affected Persons:** Users (e.g., website visitors, users of online services).
**Purposes of Processing:** Provision of our online offering and user-friendliness; marketing; profiles with user-related information (creation of user profiles).
**Legal Basis:** Consent (Art. 6(1)(a) GDPR), with the right to withdraw consent (Art. 7(3) GDPR); legitimate interests, improving the online offering and expanding marketing (Art. 6(1)(f) GDPR).

**Further Information on Processing Operations, Procedures, and Services:**
**Facebook Plugins and Content:** Facebook Social Plugins and content – This may include content such as images, videos, or texts and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “event data” that Facebook collects or receives through Facebook Social Plugins (and content embedding functions) executed on our online offering for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users’ interests). We have concluded a specific agreement with Facebook (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum), which regulates, in particular, the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing is not carried out under joint responsibility but based on a data processing agreement (“Data Processing Terms,” https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, based on standard contractual clauses (“Facebook EU Data Transfer Addendum,” https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection, and complaints to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.

**Instagram Plugins and Content:** Instagram plugins and content – This may include content such as images, videos, or texts and buttons that allow users to share content from this online offering within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “event data” that Facebook collects or receives through Instagram functions (e.g., content embedding functions) executed on our online offering for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalization of functions and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users’ interests). We have concluded a specific agreement with Facebook (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum), which regulates, in particular, the security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain information about individual users and are anonymous to us), this processing is not carried out under joint responsibility but based on a data processing agreement (“Data Processing Terms,” https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms), and, with regard to processing in the USA, based on standard contractual clauses (“Facebook EU Data Transfer Addendum,” https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection, and complaints to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.

**LinkedIn Plugins and Content:** LinkedIn plugins and content – This may include content such as images, videos, or texts and buttons that allow users to share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data Processing Agreement: https://legal.linkedin.com/dpa; Standard Contractual Clauses (ensuring data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-Out Option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Amendment and updating of the privacy policy

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

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

As a data subject, you have various rights under the General Data Protection Regulation (GDPR), particularly arising from Articles 15 to 21 GDPR:

**Right to Object:** You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling to the extent that it is related to such direct marketing. (Contact: dataprotection@time-change.de)

**Right to Withdraw Consent:** You have the right to withdraw any consent given at any time.

**Right to Access:** You have the right to request confirmation as to whether personal data concerning you is being processed and to obtain information about this data, as well as further details and a copy of the data in accordance with legal requirements.

**Right to Rectification:** You have the right, in accordance with legal requirements, to request the completion of incomplete personal data concerning you or the correction of inaccurate personal data concerning you.

**Right to Erasure and Restriction of Processing:** You have the right, in accordance with legal requirements, to request that personal data concerning you be deleted without undue delay or, alternatively, to request restriction of the processing of such data in accordance with legal requirements.

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

**Right to Lodge a Complaint with a Supervisory Authority:** Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

For further details or to exercise these rights, you can contact the data controller at the provided email (dataprotection@time-change.de) or, where applicable, the service providers (e.g., Meta Platforms Ireland Limited, LinkedIn Ireland Unlimited Company) as outlined in their respective privacy policies provided in earlier responses.