What this policy covers?

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand.

1 An overview of data protection

1.1 General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this online offering. The term personal data comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

1.2 Data recording on this online offering

Who is the responsible party for the recording of data on this online offering (i.e., the “controller”)?

The data on this online offering is processed by the operator of the online offering, whose contact information is available under section Information about the responsible party (referred to as the controller in the GDPR) in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance, be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your visit of our offering. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this online offering.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when you visit this online offering. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs, please consult our Data Protection Declaration below.

2 Hosting

We are hosting the content of our online offering at the following provider.

2.1 External Hosting

This online offering is hosted externally. Personal data collected on this online offering are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR).

Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host(s) DigitalOcean LLC

101AvenueoftheAmericas,2ndFloor
NewYork,NY10013,USA
registered under the Data Privacy Framework, for further information please to https://www.digitalocean.com/legal/gdpr-faq and for order processing please go to https://www.digitalocean.com/legal/data-processing-agreement

Status available at https://www.dataprivacyframework.gov/s/participant-search/participant-detail contact=true&id=a2zt0000000YdenAAC&status=Active

GoDaddy.com, LLC 2155 E GoDaddy Way, Tempe, Arizona 85284, USA
registered under the Data Privacy Framework, for further information please go to https://www.godaddy.com/de-at/legal/agreements/data-privacy-framework-notice and for dataprocessing https://www.godaddy.com/en-il/legal/agreements/data-processing-addendum

Status available under https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000YdenAAC&status=Aktiv

Framer B.V. Rozengracht 207B Amsterdam, 1016 LZ, Niederlande

for further information, see https://www.framer.com/help/articles/gdpr-and-cookies/ and for order processing, see https://www.framer.com/legal/data-processing-addendum/

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our online offering visitors only based on our instructions and in compliance with the GDPR. If and to the extent that data is transferred to third countries, please refer to section 3.

3 General information and mandatory information

3.1 Data protection

The operators of this online offering and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this online offering, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

3.2 Information about the responsible party (the “controller” in the GDPR)

The data processing controller on this online offering is

Housing Connect GmbH
Belvederestr 40
50933 Koeln
Germany

Phone: +49 (0)152 52450331
E-mail: support@housingpass.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

3.3 Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in that case, the deletion will take place after these reasons cease to apply.

3.4 General information on the legal basis for data processing on this online offering

If you have consented to data processing, we process your personal data on the basis ofArt. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device(e.g., viadevice fingerprinting),thedataprocessingisadditionally based on§25 (1)TTDSG.The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

We use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data protection law.

We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted i the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances. Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy, in each case in connection with the description of the processing by the corresponding recipients (for the hosters used, see section 2)

Information on the registration status of individual participants under the DPF can be found here https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt0000000YdenAAC&status=Active

3.5 Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing,ajointprocessingagreement is concluded.

If you actively use our Housingpass offer and use it to provide content to potential landlords, they will receive the data you have released - solely under your control.

3.6 Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You may revoke consent you have previously granted at any time. This shall not affect the legality of data already processed prior to your revocation.

3.7 Right to object to data collection in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THEEVENT THAT DATAAREPROCESSED ON THEBASISOFART. 6(1)(E) OR (F) GDPR,YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING ISTHE CLAIMING, EXERCISING OR DEFENCE ßOF LEGAL ENTITLEMENTS (OBJECTION PURSUANTTOART.21(1)GDPR).

IFYOUR PERSONAL DATAISBEING PROCESSED IN ORDER TO ENGAGEIN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING ATANYTIME. THIS ALSO APPLIESTO PROFILING TO THE EXTENT THAT ITISAFFILIATED WITH SUCH DIRECTADVERTISING. IFYOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANTTOART.21(2) GDPR).

3.8 Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, affected individuals have the right to lodge a complaint with a supervisory authority, particularly in the member state of their habitual residence, workplace, or the place where the alleged violation occurred.

3.9 Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or a third party in a commonly used, machine-readable format. A direct transfer to another controller will only occur if technically feasible.

3.10 Information, rectification and deletion of data

Within the scope of applicable legal provisions, you have the right to receive information about your stored personal data, their origin, recipients, and the purpose of data processing at any time, as well as the right to rectification or deletion. If you have further questions, you may contact us at any time.

3.11 Right to restrict data processing

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in thefollowingcases: In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data. If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication. If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data. If you have restricted the processing of your personal data, these data - with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

3.12 SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the online offering operator, this online offering uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If SSL or TLS encryption is activated, data you transmit cannot be read by third parties.

3.13 Encrypted payment transactions

If you are under an obligation to share your payment information (e.g. account numberif you give us the authority to debit your bank account) with us after you have entered into a feebased contract with us, this information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whetherthe address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you sharewith us.

3.14 Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this online offering and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4 Recording of data on this online offering

4.1 Cookies

Our online offerings and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into online offerings (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain online offering functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the online offering (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of this online offering has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this online offering may be limited.

Which cookies and services are used on this online offering can be found in this privacy policy.

4.2 Consent with Cookie Notice & Compliance

Our online offering uses the consent technology of Cookie Notice & Compliance for GDPR to obtain your consent for the archiving of certain cookies on your device or for the use of certain technologies and for the data protection compliant documentation of the former.

Cookie Notice & Compliance for GDPR is installed locally on our servers so that a connection with third party servers does not occur. Cookie Notice & Compliance for GDPR stores a cookie in your browser to be able to allocate the granted consent and their revocation to you. The cookie stays active for 1 month. Your data is stored until you ask us to delete it, delete the consent cookie yourself or the purpose of data archiving is no longer valid. This does not affect mandatory statutory retention periods.

Cookie Notice & Compliance for GDPR is being used to obtain the consent for the use of cookies required by law. The legal basis is Art. 6(1)(c) GDPR.

4.3 Typeform

We have integrated Typeform on this online offering. The provider is TYPEFORM S.L., Carrer Bac de Roda, 163, 08018 Barcelona, Spain (hereinafter “Typeform”).

Typeform enables us to create online forms and integrate them into our online offering. The data you enter in our Typeform forms is stored on Typeform’s servers until you ask us to delete it, revoke any consent you have given to store it, or the purpose for storing the data no longer applies (e.g., after we have finished processing your request). Mandatory legal provisions – in particular, retention periods – remain unaffected by this.

The use of Typeform is based on Art. 6(1)(f) GDPR. The operator of this online offering has a legitimate interest in functioning online forms. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of the visitors of our online offering only based on our instructions and in compliance with the GDPR.

4.5 Registration on this online offering / usage of this service Housingpass

You have the option to register on this online offering to be able to use additional functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.

We shall process the data entered during the registration process on the basis of your consent (Art. 6(1)(a) GDPR).

The data recorded during the registration process shall be stored by us as long as you are registered on this online offering. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

4.6 Registration with Google

Instead of registering directly on this online offering, you can register with Google. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To register with Google, you must only enter your Google name and password. Google will identify you and confirm your identity to our online offering.

When you sign in with Google, we may be able to use certain information in your account to complete your profile with us. You decide whether you want this information to be used and if so, which information it is, within the framework of your Google security settings, which you can find here https://myaccount.google.com/security and https://myaccount.google.com/permissions

The data processing associated with Google’s registration is based on our legitimate interest in making the registration process as simple as possible for our users (Art. 6(1)(f) GDPR). Since the use of the registration function is voluntary and the users themselves can decide on the respective access options, no conflicting predominantrights of the data subjects areapparent.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt000000001L5AAI&status=Active

4.7 Data processing as part of the “Housingpass” product

If and insofar as you actively use Housingpass and have set up a profile, you have the option of processing the following data from the external sources you have provided (e.g. your bank details) as well as your own personal data via Housingpass. You can use this to create an “application document” that you can make available to potential landlords.

The application document generated in this way then contains the following data: First and last name address Date of birth Number and other details of identity card or passport age sex Nationality Information on marital status Details of employment Net household income Job title and name of employer Details of last rented apartment and tenant Smoking behavior Details of pets Account balance and bank transactions Details of financial situation Details of liability insurance

It will remain stored in the Housingpass system until you delete it or the contractual relationship with us is terminated.

We do not pass on the application documents to third parties. This is controlled solely by you as the user.

The legal basis for this processing is Art. 6 para. 1 lit. b GDPR (contract, i.e. your contract with us), as well as Art. 6 para. 1 lit. a GDPR with regard to the transfer to third parties controlled by you.

5 Social media

5.1 LinkedIn

This online offering uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Any time you access a page of this online offering that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this online offering with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this online offering to your user account. We have to point out that we as the provider of the online offering do not have any knowledge of the content of the transferred data and its use by LinkedIn. The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TTDSG. Consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-demewr-und-der- schweiz?lang=en

For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at https://www.linkedin.com/legal/privacy-policy

6 Analysis tools and advertising

6.1 Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our online offering. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The operator of this online offering has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his online offering. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participantdetail?contact=true&id=a2zt000000001L5AAI&status=Active

6.2 Google Analytics

This online offering uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the operator of this online offering to analyze the behavior patterns of online offering visitors. To that end, the operator of this online offering receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is summarized in a user-ID and assigned to the respective end device of the online offering visitor.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis. Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The online offering use information recorded by Google is, as a rule, transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here https://privacy.google.com/businesses/controllerterms/mccs/

IP anonymization

Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this online offering, Google shall use this information to analyze your use of this online offering to generate reports on online offering activities and to render other services to the operator of this online offering that are related to the use of the online offering and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link https://tools.google.com/dlpage/gaoptout?hl=en.

Google Signals

We use Google Signals. Whenever you visit our online offering, Google Analytics records, among other things, your location, the progression of your search and YouTube progression as well as demographic data (site visitor data). This data may be used for customized advertising with the assistance of Google Signal. If you have a Google account, your site visitor information will be linked to your Google account by Google Signal and used to send you customized promotional messages. The data is also used to compile anonymized statistics of our users’ online patterns.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Google Analytics E-Commerce Tracking

This online offering uses the “E-Commerce Tracking” function of Google Analytics. With the assistance of E-Commerce Tracking, the online offering operator is in a position to analyze the purchasing patterns of online offering visitors with the aim of improving the operator’s online marketing campaigns. In this context, information, such as the orders placed, the average order values, shipping costs and the time from viewing the product to making the purchasing decision are tracked. These data may be consolidated by Google under a transaction ID, which is allocated to the respective user or the user’s device.

7 Newsletter

7.1 Newsletter data

If you would like to receive the newsletter offered on the online offering, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.

7.2 Mailchimp with deactivated success measurement

This online offering uses the services of Mailchimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Among other things, Mailchimp is a service that can be deployed to organize the sending of newsletters. Whenever you enter data forthe purpose of subscribing to a newsletter(e.g. your e-mail address), the information is stored on Mailchimp servers in the United States. We have deactivated the success measurement of Mailchimp, so Mailchimp will not evaluate your behavior when opening our newsletter.

If you do not want Mailchimp to receive your data, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

The data is processed based on your consent(Art. 6(1)(a) GDPR).You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found herehttps://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_- _Standard_Contractual_Clauses

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interes twith in the meaning of Art. 6(1)(f)GDPR).The storage in the black list is indefinite. You may object to the storage if your interests outweigh ourlegitimate interest.

For more details, please consult the Data Privacy Policies of Mailchimp at:https://mailchimp.com/legal/terms/.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of the visitors of our online offering only based on our instructions and in compliance with the GDPR.

8 Plug-ins andTools

8.1 Sentry

We have integrated Sentry on this online offering. The provider is Functional Software Inc., 45 Fremont Street, 8th Floor, San Francisco, California 94105, USA.

Sentry is an open-source bug tracking service that allows us to monitor and fix bugs and crashes anywhere in a web-based software in real time.

Sentry is used on the basis of Art. 6 (1)(f) GDPR. The operator of this online offering has a legitimate interest in the error- free functioning of its own website.

If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of theTTDSG.This consent can be revoked at any time.

For more details, please refer to the providers privacy policy https://sentry.io/privacy/

Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be foundhere.

https://sentry.io/legal/dpa/5.0.0/#cross-border-transfermechanisms und https://sentry.io/legal/dpa/5.0.0/#thirdparty

Data processing

9 Ecommerce and payment service providers

9.1 Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this online offering (usage data) will be collected, processed, and used only if this is necessary to enable the userto use our services or required for billing purposes. The legal basis for these processes isArt. 6(1)(b) GDPR.

9.2 Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

9.3 Payment services

We integrate payment services of third-party companies on our online offering. When you make a purchase from us,your payment data(e.g.name,payment amount, bank account details,credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f)GDPR).Insofar as your consent is requested for certain actions,Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this online offering.

9.4 Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock,Dublin, Ireland (hereinafter“Stripe”).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here https://stripe.com/de/privacy and https://stripe.com/de/guides/general-dataprotection-regulation

Details can be found in Stripe’s Privacy Policy at the following link https://stripe.com/de/privacy

10 Custom Services

10.1 Handling applicant data

We offer visitors of our online offering the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidentia

10.2 Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

10.3 Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required afterthe expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.

10.4 Admission to the applicant pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntaryand has norelationtothe ongoing application procedure. The affected person can revoke his agreement at any time. In this case, the data from the applicant poolwillbe irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.

What this policy covers?

1 An overview of data protection

Who is the responsible party for the recording of data on this online offering (i.e., the “controller”)?

How do we record your data?

What rights do you have as far as your information is concerned?

Analysis tools and tools provided by third parties

2 Hosting

Data processing

3 General information and mandatory information

4 Recording of data on this online offering

5 Social media

6 Analysis tools and advertising

Google Signals

Contract data processing

Google Analytics E-Commerce Tracking

7 Newsletter

Data processing

8 Plug-ins andTools

Data processing

9 Ecommerce and payment service providers

10 Custom Services

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