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Privacy Center

In our data protection center, we provide you with all the documents required for the GDPR in one place. In addition, you will find our service catalog, an overview of our subcontractors, and information about our technical and organizational measures (TOM) to protect your data and that of your customers.
You can download the latest version of our contract for commissioned data processing here.

You can download the latest version of our technical and organizational measures (TOMs for short) here.

Specification of services

Business Applications

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Technical (further) development of the Salesforce customer instance, consulting, and project management Read access to the Salesforce platform in order to provide advice based on the data and its structure Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers
Technical (further) development of the Salesforce customer instance, administration Read and write access to the Salesforce platform in order to maintain the platform Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers
Technical (further) development of the Salesforce customer instance, programming Read and write access to the Salesforce platform in order to further develop the platform Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers
Technical (further) development of the Salesforce customer instance, consulting on system architecture Read access to the Salesforce platform in order to provide advice based on the data and its structure Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers
Technical (further) development of the Salesforce customer instance, evaluation of analysis results and mass data Read and write access to the Salesforce platform in order to evaluate the data Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers
Technical development of mobile apps, programming Read and write access to mobile apps, databases, and servers in order to further develop mobile applications Access to all data stored in the Salesforce customer instance, e.g., communication data (e.g., telephone, e-mail, address), contract master data (contractual relationship, product or contract interest), customer history, order, billing, and payment data, planning and control data, information (from third parties, e.g., credit agencies, or from public directories), credit information, personal information, criminal records, and potentially any electronic communication. Subscribers
Employees
Prospective customers
Suppliers
Sales representatives
Customers
Competitors
Partners
Job applicants
Consumers

Online presence
(Websites, Landing pages, Online apps, etc.)

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Technical work on the online presence Access to content and user data stored in the content management system for technical processing and expansion of the platform. Access to log files for securing the server/website. Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g., credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Editorial work on the online presence Access to content stored in the content management system, such as contact details of contact persons. Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g., credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Digital strategy / strategic
(further) development of online platforms / consulting
If applicable, access to analysis data for evaluating user behavior.
Access to content and user data stored in the content management system.
Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g., credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Development of an online presence including consulting, design, and programming If applicable, access to analysis data for evaluating user behavior.
Access to content intended for the website, such as contact persons, in order to transfer this information to the website.
Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g., credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

Online-Shop

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Technical processing of the online shop Access to user data and content stored in the online shop for technical processing.
Access to log files to secure the server / the online shop.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Editorial work on the online shops Access to content of the online shop, such as contact persons. Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Conceptualization and implementation of an online shop including consulting, design, and programming If applicable, access to analysis data for evaluating user behavior.
Access to content intended for the web shop, such as contact persons, in order to transfer this information to the website.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Digital strategy / strategic
(further) development of the online shop
If applicable, access to analysis data for evaluating user behavior.
If applicable, access to user accounts for analyzing purchasing behavior and optimizing the shopping experience.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Technical further development of the online shop Access to user data and content stored in the online shop for technical administration.
Access to log files to secure the server / the online shop.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

Hosting

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Hosting of the website By providing web space and databases, we may potentially have access to visitor data and website content.
Access to log files.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Hosting of the online shop By providing web space and databases, we may potentially have access to customer data and website content.
Access to log files.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Hosting of a development environment By providing a development environment, we may potentially have access to data stored in the databases and on the web space. Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

SEO & Online-Marketing

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Management of online campaigns Access to analysis tools / analysis results for evaluating user behavior. Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Consulting on online marketing (including analysis of results) Access to analysis tools / analysis results for evaluating user behavior. Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Search engine optimization (on-page and off-page) Access to analysis tools / analysis results for evaluating user behavior.
Access to website content.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

Newsletter

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Management of email marketing campaigns Access to recipient information for managing email campaigns.
Access to newsletter tracking.
Access to newsletter content.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Creation of newsletters including consulting, design, programming, and testing Access to newsletter content Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Sending of newsletters Access to recipient information for sending newsletters.
Access to newsletter content.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Management of newsletter recipients Access to recipient information for sending newsletters.
Access to newsletter content.
Personal master data
Communication data (e.g. telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g. credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

(Offline-)Marketing

Subject Nature and purpose of processing Data types/categories Categories of data subjects
Creation of a marketing concept (with evaluation of analysis data) Access to analysis tools and analysis results, if applicable.
Access to content for marketing measures.
Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Planning and control data
Information (from third parties, e.g., credit agencies, or from public sources) Verzeichnissen)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons
Creation of print media Access to content for print media. Personal master data
Communication data (e.g., telephone, email)
Contract master data (contractual relationship, product or contract interest)
Customer history
Contract billing and payment data
Planning and control data
Information (from third parties, e.g., credit agencies, or from public directories)
Customers
Prospective customers
Subscribers
Employees
Suppliers
Sales representatives
Contact persons

Subcontractor

Hosting

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
Amazon Web Services, Inc., USA mixed Hosting, IaaS, PaaS
Cloudflare, Inc, USA mixed Hosting, CDN
domainfactory GmbH, DE DE, FR Hosting
Google Cloud Platform (GCP) mixed IaaS, PaaS
Hetzner Online GmbH, DE DE Hosting
Host Europe GmbH, DE FR Hosting
maxcluster GmbH DE Hosting
Mittwald CM Service GmbH & Co. KG, DE DE Hosting

Marketing

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
CleverReach GmbH & Co. KG, DE EU Newslettersystem
Dotmailer Limited UK Marketing Automation
Inxmail GmbH, DE DE Newslettersystem
MailChimp, USA US Newslettersystem
Salesforce Marketing Cloud EU Marketing Automation
PARDOT EMEA, UK UK Marketing Automation
Vimeo.com, Inc. USA Streaming Software Platform

Service provider

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
VRP Consulting NL Development
Agile Networks Technologies GmbH DE Development
NICKLAS+NICKLAS CH Development
Omikron Data Solutions GmbH DE Development
AWESOME Software GmbH DE Development
KCS IT S.A PT Development

Freelancer

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
Anastassia Khasinevich PL Development
Eduard Dehgraf CH Consulting
Thomas Wegener DE Consulting

Tracking

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
Google Ireland Limited, IRL mixed Tracking 
etracker GMBH, DE DE Tracking 

Advertisement

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
DataValidation by Synapp.io EU  
Facebook Ireland Limited, IRL mixed Werbeplattform 
Google Ireland Limited, IRL mixed Werbeplattform 
HubSpot Inc., USA DE, US Werbeplattform 
LinkedIn Ireland Unlimited Company, IRL mixed Werbeplattform 
Outbrain UK Limited, UK mixed Werbeplattform 
Plista GmbH, DE mixed Werbeplattform 
Taboola, Inc., USA mixed Werbeplattform 
Xing, SE, DE mixed Werbeplattform 

Tools

Subcontractor (name, legal form, registered office of the company) Processing site Type of service
salesforce.com Germany GmbH, DE DE, FR CRM-System, Auftragsverwaltung
Atlassian (JIRA,Confluence,Trello), USA EU Ticketsystem und Dokumentverwaltung des Auftragnehmers
Google LLC, USA EU Cloud-Basierte Office Applikationen und Dokumentenablage, Google G Suite 
Slack Technologies, USA EU Software zur Teamkommunikation 
Adobe Systems Software Ireland Limited, IRL EU Creative Cloud, Software as a Service, Cloud-Speicher 
Apple Distribution International, IRL EU iCloud, Cloud Speicher
SiteLock , USA EU Website Security
AgileBits, Inc., CAN EU 1Password, Passwortverwaltung 
Microsoft Corporation, USA EU Office365 
REISSWOLF Archivservice GmbH, DE DE Akten-, und Datenvernichtung 
Sage GmbH DE Buchhaltung/Rechnungswesen 
Robin EU Raumplanung
BMW Bank GmbH DE Fahrzeugleasing
Volkswagen Leasing DE Fahrzeugleasing
COFACE RATING GMBH DE Auskunftei/Forderungsversicherung
DATEV eG, Nürnberg DE Gehaltsabrechnung
Personio SE & Co. KG DE Personalprozesse

Technical and organizational measures

Stand: 30.06.2023

1. Confidentiality (Art. 32 Abs. 1 DS-GVO)

Pseudonymization

(Art. 32 Abs. 1 lit. a DS-GVO; Art. 25 Abs. 1 DS-GVO)
The processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to appropriate technical and organizational measures:

-  Encryption of data records
-  Pseudonymization: separation of the attribution file
-  Transfer of data in anonymized and pseudonymized form

Access control

No unauthorized system use, e.g.: (secure) passwords, automatic locking mechanisms, two-factor authentication, encryption of data carriers:

- Alarm system
- Automatic access control system
- Personnel control
- Locking system
- Key chip control
- Video surveillance
- Visitor logging
- Selection of external contractors in-house/cleaning/security service
- Light barriers and motion detectors

Data carrier check

- Locking external interfaces
- Encryption of laptops/notebooks
- Encryption of smartphone content
- Encryption of data carriers
- Smartphone admin software MDM

Memory check

- Anti-virus software
- Hardware firewall
- Software firewall

User control

- Creation of user profiles
- Assignment of user profiles to IT systems
- VPN technology

Access control

No unauthorized reading, copying, modification, or removal within the system, e.g.: Authorization concepts and needs-based access rights, logging of accesses:

- Creation of an authorization concept
- Authentication with name and password
- Number of administrators reduced to “necessity”
- Password assignment and policy
- Logging of access/input/changes/deletions
- Storage of data carriers
- Proper disposal of data carriers/documents
- Establishment of a dedicated line
- Email encryption
- Documentation of data recipients and time periods
- Creation of an overview of regular retrieval and transmission processes

Separability

No unauthorized reading, copying, modification, or removal within the system, e.g.: Authorization concepts and needs-based access rights, logging of accesses:

- Creation of an authorization concept
- Authentication with name and password
- Number of administrators reduced to “necessity”
- Password assignment and policy
- Logging of access/input/changes/deletions
- Storage of data carriers
- Proper disposal of data carriers/documents
- Establishment of a dedicated line
- Email encryption
- Documentation of data recipients and time periods
- Creation of an overview of regular retrieval and transmission processes

2. Integrity (Art. 32 Abs. 1 lit. b DS-GVO)

Input control

- Logging of data entry/modification/deletion
- Traceability of entry/modification/deletion
- Assignment of rights for entry/modification/deletion
- Authorization concept
- Overview of applications for entry/modification/deletion
- Storage of forms for automated processing

Transport control

No unauthorized reading, copying, modification, or removal during electronic transmission or transport, e.g.: encryption, virtual private networks (VPN), electronic signature:
‍
- Careful selection of transport personnel and vehicles
- Physically secure transport containers

Data integrity

- Definition of safety-critical systems
- Safety & Security

3. Availability and resilience
(Art. 32 Abs. 1 lit. b DS-GVO)

Availability

Protection against accidental or deliberate destruction or loss, e.g.: backup strategy (online/offline; onsite/off-site), uninterruptible power supply (UPS), virus protection, firewall, reporting channels, and emergency plans:

- UPS
- Monitoring of temperature and humidity in the server room
- Air conditioning in the server room
- Fire and smoke detection
- Alarm in case of unauthorized access to the server room
- Emergency plan
- Security concept
- Alarm system (fire extinguishers, alarm center, etc.)
- Location of the server room (on site, both internally and externally)

Recoverability

- Data backup type/scope/outsourcing
- Backup and recovery concept

4. Procedures for regular review, assessment, and evaluation (Art. 32 Abs. 1 lit. d DS-GVO; Art. 25 Abs. 1 DS-GVO)

Data protection management

Data protection employee agreements, encryption, passwords, access control, TOMs, updating the procedure directory, availability check

Incident-Response-Management (Incident risk) 

Employee training Risk and impact assessment, damage containment, elimination of the cause, restoration of affected systems, documentation, analysis

Privacy-friendly default settings (Art. 25 Abs. 2 DS-GVO) 

Privacy by Design - Design and development of IT systems in compliance with data protection regulations Privacy by Default - Databases and user group rights

Order control

No order data processing within the meaning of Art. 28 GDPR without corresponding instructions from the client, clear contract design, formalized order management, such as follow-up checks of technical and organizational measures.

- Selection of the contractor
- Order processing Art. 28
- Effective control rights / contractual penalty Art. 32
- Instruction of employees Art. 29
- Ensuring the destruction/deletion of data after termination
- Ongoing review of the contractor / activities
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