Privacy and data protection

Last updated on 04 March 2024

1. General information and mandatory information

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy. When you use this website, various pieces of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens. Please note that data transmitted via the internet (e.g. via e-mail communication) may be subject to security breaches. Complete protection of your data from third-party access is not possible.

Information regarding the party responsible for this website

The party responsible for processing data on this website is:
DICTUM GmbH
Gottlieb-Daimler-Str. 3
94447 Plattling
Germany
Telephone: +49 (0)9931 4058-100
E-Mail: privacy@dictum.com

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, e-mail addresses, etc.).

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as the enquiries you send to us as the site operator. You can recognise an encrypted connection by the »https://« at the beginning of your browser's address line and the lock icon displayed within your browser's address bar. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.

Encrypted payments on this website

If you enter into a contract which requires you to send us your payment information (e.g. account number for direct debits), this is because we need this data to process your payment. Payment transactions using common means of payment (Visa/MasterCard/American Express, direct debit) are only made via encrypted SSL or TLS connections. You can recognise an encrypted connection by the »https://« at the beginning of your browser's address line and the lock icon in your browser’s address bar. In the case of encrypted communication, none of the payment details you submit to us can be read by third parties.

Objection to promotional e-mails

We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements for sending promotional and informational materials not expressly requested. The website operators reserve the right to take specific legal action if unsolicited advertising material, such as e-mail spam, is received.

2. Data protection officer

Statutory data protection officer

We have appointed a data protection officer for our company.
E-Mail: datenschutzbeauftragter@datenschutzexperte.de

3. Access to and storage of information in terminal equipment

By using our website, access to information (e.g. IP address) or storage of information (e.g. cookies) in your terminal equipment may occur. This access or storage may involve further processing of personal data pursuant to the GDPR.
In cases where such access to information or such storage of information is strictly necessary for the technically error-free delivery of our services, this is done on the basis of § 25 para. 1 s. 1, para. 2 no. 2 TDDDG (German Data Protection and Privacy of Telecommunication and Telemedia Services (TDDDG) Act).
In cases where such a process serves other purposes (e.g. the needs-based design of our website), this will only be carried out on the basis of § 25 para. 1 TDDDG with your consent pursuant to Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time with effect for the future. For more information on the processing of your personal data and the relevant legal basis in this context, please refer to the following sections on the specific processing activities on our website.

4. Data collection on our website

Cookies

Some of our web pages use cookies. Cookies help make our website more user-friendly and enable its functionality. Cookies are small text files that are stored on your computer and saved by your browser. Some of the cookies we use are »session cookies«. They are automatically deleted after your visit. Other cookies (»persistent cookies«) remain on your device and enable us to recognise your browser on your next visit. If cookies are activated, they collect and process certain user information on an individual basis, such as browser and location data, as well as the IP address. »Persistent cookies« are automatically deleted after a specified period of time, which may vary depending on the cookie. You can see the storage duration of the respective cookie in the overview of the cookie settings of your web browser.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the contents of a virtual shopping basket for a later visit to the website). Insofar as personal data is also processed by individual cookies used by us, processing is carried out pursuant to Art. 6 (1) (b) GDPR, either for the execution of the contract, pursuant to Art. 6 (1) (a) GDPR in the case of a granted consent, or pursuant to Art. 6 (1) (f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective site visit.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Every browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:

Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: https://support.google.com/chrome/answer/95647?hl=en&amp%3Bhlrm=en
Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/12.0/mac/10.14
Opera: https://help.opera.com/en/latest/web-preferences/

Disabling cookies may limit the functionality of this website.

You can change your personal cookie settings for this website here.

You can find an overview of all cookies below:

Local storage

In addition to cookies, we also use Local Storage technology (also called »Local Data«). Data is stored locally in the cache of your browser, which continues to exist and can be read even after closing the browser window or exiting the program – as long as you do not clear the cache. With Local Storage, your preferences when using our websites are stored on your computer and used by you. The data from the Local Storage is used, for example, to give you recommendations based on your anonymous usage or to enable you to create a watch list.

The data stored in Local Storage cannot be accessed by third parties, nor is it passed on to third parties or used for advertising purposes. We use these techniques in our legitimate interest in order to be able to make you a fully functional offer on the basis of Art. 6 (1) (f) GDPR.

You can manage Local Storage contents in the browser via the settings for »Browser History« or »Local Data«, depending on which browser you use. If the functions are restricted, functional limitations may occur.

Data collection when visiting our website

When using our website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser sends to our server (known as »server log files«). When you visit our website, we collect the following data, which is technically necessary for us to display the website:

• Our visited website
• Date and time of access
• Amount of data sent in bytes
• Source/reference from which you reached the site
• Browser type and browser version
• Operating system used
• IP address

Processing is carried out in accordance with Art. 6 (1) (f) GDPR based on our justified interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently if there are concrete indications of illegal use.

Contact form

Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, only process any data you enter onto the contact form with your consent per Art. 6 (1) (a) GDPR and our legitimate interest in answering your request in accordance with Art. 6 (1) (f) GDPR. You may revoke your consent at any time. An informal e-mail making this request is sufficient. The legality of the data processing operations carried out up to the time of revocation shall remain unaffected by the revocation.
If the purpose of your contact with us is the conclusion of a contract, this additional legal basis for data processing is covered by Art. 6 (1) (b) GDPR. We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.

»Item back in stock« form

This function is available to website visitors if an item is currently unavailable and so cannot be ordered. In this case, you can opt to receive an e-mail notifying you when the item is back in stock and available to order. To fulfil this request, we store the e-mail address you provide. We will not pass this on without your consent.
We use the »double opt-in procedure« to send this notification. This means that we will not send you any such notification until you have expressly confirmed to us that you agree to receive such a message. We will then send you a confirmation email asking you to confirm that you wish to receive such a notification by clicking on the appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Art. 6 (1) (a) GDPR. You may revoke this consent at any time. An informal e-mail making this request is sufficient. The legality of the data processing operations carried out up to the time of revocation shall remain unaffected by the revocation.

The data you provide in the »Item back in stock« form will remain with us until you ask us to delete it, or withdraw your consent to its storage, or the data is no longer needed for the purpose for which it was stored. This does not affect mandatory legal requirements – in particular retention periods.

Registration on this website

You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject your registration. To inform you about important changes such as those regarding the scope of our site or technical changes, we will use the e-mail address specified during registration.
We will only process the data provided during registration based on your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time. An informal e-mail making this request is sufficient. The legality of the data processing operations carried out up to the time of revocation shall remain unaffected by the revocation.
We will continue to store the data collected during registration for as long as you remain registered on our website and then delete them. Statutory retention periods remain unaffected.

Processing of data (customer and contract data)

We collect, process, and use personal data only insofar as it is necessary to establish or modify legal relationships with us (master data). This is performed according to Art. 6 (1) (b) GDPR, which allows the processing of data to fulfil a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same. Furthermore, your data will be used for the purposes of advertising and market research by the responsible body.
Collected customer data shall be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

Data transmitted for order processing

To process your order, we cooperate with the following service providers, who support us in whole or in part in the execution of concluded contracts. Certain personal data will be transmitted to these service providers in accordance with the following information.
The personal data collected by us will be passed on to the transport company commissioned with the delivery as part of the contract process insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the assigned credit institute as part of the payment process if this is necessary to process the payment. If payment service providers are used, we shall inform you explicitly about this. The legal basis for the transfer of data is Art. 6 (1) (b) GDPR.
In order to fulfil our contractual obligations towards our customers, we work together with external shipping partners. We will pass on your name as well as your delivery address and, if necessary for the delivery, your telephone number, exclusively for the purpose of delivering the goods Art. 6 (1) (b) GDPR to a shipping partner selected by us.

Use of special service providers for order processing and order handling on platforms

Order processing is performed by the service provider »magnalister« (RedGecko GmbH, Paul-Lincke-Ufer 20-22, 10999 Berlin, Germany). Name, address and, if applicable, other personal data are passed on to magnalister in accordance with Art. 6 (1) (b) GDPR exclusively for processing the online order. Your data will only be passed on as far as this is actually necessary for the processing of the order. Details on privacy at magnalister and its data protection declaration can be viewed on the magnalister website https://www.magnalister.com/en/privacy/.

Course surveys

After participating in one of our workshops, you will receive an access code to our online course survey, where you have the option to state your own opinion about the course you have attended. We store the data you enter for the purpose of continuously improving our offers and course procedures. Data processing is carried out based on your consent in accordance with Art. 6 (1)(a) GDPR. You may revoke this consent at any time. An informal email to this effect is sufficient. The legality of the data processing operations carried out up to the time of revocation shall remain unaffected by the revocation.

Transfer of customer and contract data to manufacturers for the purpose of offering an extended warranty

As part of our offer, we cooperate with manufacturers who grant extended warranty on their devices, provided that they have been registered. For more information about how to obtain the extended warranty, please see the related item page at www.dictum.com. If you purchase any devices from these manufacturers, we will grant you a free product registration with the manufacturer on your behalf as part of the purchase contract. Upon conclusion of a purchase contract, the customer's data recorded by our company (name, address, e-mail address as provided by the customer) are provided to the manufacturer for the purpose of registering the device.

Playback of YouTube videos

This website uses the YouTube embedding feature to display and play videos from the provider »YouTube«, which belongs to Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (»Google«).

The extended data protection mode is used here, which, according to the provider, only starts storing user information when playback of the video(s) starts and continues during playback. If the playback of embedded YouTube videos is started, the provider »YouTube« uses cookies to collect information about user behaviour. According to information from »YouTube«, this is used, among other things, to collect video statistics, improve user-friendliness and prevent abusive practices. If you are logged in to Google, your information will be associated directly with your account when you click on a video and confirm the corresponding notification box. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. Google stores your data (even for users who are not logged in) as user profiles and evaluates them. Such an evaluation is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of Google's justified interests in the insertion of personalised advertising, market research and/or needs-based design of its website. You have the right to object to the creation of these user profiles, and you must contact YouTube to exercise this right. In the course of using YouTube, personal data may also be transmitted to the servers of Google LLC. in the USA.

For more information on data protection at »YouTube«, please refer to the provider's privacy policy at: https://www.google.de/intl/en/policies/privacy.

Insofar as legally required, we have obtained your consent to the processing of your data as described above in accordance with Art. 6 (1) (a) GDPR prior to processing. This is performed by means of a message which has to be confirmed before playing the video.

Use of the Sovido plugin and the Sovido platform

(1) We use a plugin and a connection to the video platform Sovido to display audiovisual content. Sovido is a platform for the production, processing and distribution of audiovisual content and related services and is provided to us by Sovido GmbH, Vor dem Bardowicker Tore 6a, 21339 Lüneburg, Germany.

(2) Sovido GmbH collects on our behalf the following data for the use of the offered audiovisual content:

• IP address (in pseudonymised form)
• Timestamp (i.e. date and time of access to the video)
• User agent
• Format (i.e. resolution and quality) in which the video is played

(3) In the course of this procedure, Sovido GmbH will provide us with information about personal data, such as your IP address (in pseudonymised form) and other non-personal data, which is necessary for statistical purposes.

5. Data processing in the context of competitions on social media platforms

We process your personal data for the proper execution and handling of competitions and in particular for the dispatching of the prize.
In order to carry out the competition, the profile name used on the relevant platform and, if available, the first name and surname of the respective participant are collected and stored. To determine the minimum age for participation, it may be necessary to enter the date of birth. In order to send the prize, we also collect the winner’s/winners’ surname and first name and address, and pass this data on to a shipping company commissioned by us. Your data will not be passed on to third parties beyond this.
The legal basis for this processing of your personal data is Art. 6 para. 1 letter b GDPR (implementation of pre-contractual measures and performance of a contract).
If participation in the competition is made dependent on your consent to receive our newsletter, we will also collect your e-mail address for the purpose of sending the newsletter (to avoid repetition, please refer to the »Advertising/Newsletter« section here).

6. Analytics and advertising

Google Analytics

This website uses Google Analytics, a web analytics service. It is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses cookies. These are text files that are stored on your computer and make it possible to analyse how you use the website. The information generated by the cookie about your use of this website is usually transmitted to and stored on a Google server in the USA.
Google Analytics cookies are stored based on your consent per Art. 6 (1)(a) GDPR.

IP anonymisation

We have activated the IP anonymisation feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objecting to the collection of data

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics. For more information about how Google Analytics handles user data, see Google's privacy policy:

Contract data processing

We have concluded a Data Processing Agreement with Google for the use of Google Analytics, which obliges Google to protect the data of our site visitors and not to pass it on to third parties. For the transmission of data from the EU to the USA, Google relies on standard data protection clauses of the European Commission, which are intended to guarantee compliance with the European data protection level within the USA. Further information on Google (Universal) Analytics can be found here: https://policies.google.com

Demographic data collection by Google Analytics

This website uses Google Analytics' demographic features function. This allows reports to be generated containing information about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section »Refusal of data collection«.

Google Analytics Remarketing

Our website uses the functions of Google Ads Remarketing, with which we advertise this website in Google search results and on third party websites. This service is provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (»Google«). For this purpose, Google stores a cookie in the browser of your end device, which automatically enables interest-based advertising using a pseudonymous cookie ID and based on the pages you visit. Processing is carried out based on your consent in accordance with Art. 6 (1)(a) GDPR.
Any further processing of data will only take place if you have consented to Google linking your web and app browsing history to your Google Account and using information from your Google Account to personalise ads you view on the web. In this case, if you are logged in to Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data is temporarily linked by Google to Google Analytics data in order to form target groups. In the course of using Google Ads Remarketing, personal data may also be transferred to the servers of Google LLC. in the USA. You can permanently opt out of the storage of cookies for ad preferences by downloading and installing the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/
Alternatively, you can inform yourself about the storage of cookies and adjust the settings at the Digital Advertising Alliance on www.aboutads.info. Finally, you can set up your browser so that you are informed about the storage of cookies and can decide individually whether to accept them or to reject the use of cookies for certain cases or generally. If cookies are not accepted, the functionality of our website may be limited.

Further information and the privacy policy regarding advertising and Google can be found here: https://www.google.com/policies/technologies/ads/

Google AdWords and Google Conversion Tracking

This website uses the online advertising program »Google Ads« and, as part of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (»Google«). We use the services of Google Ads to draw attention to our attractive offers with the help of advertising material (»Google AdWords«) on external websites. In relation to the data of the advertising campaigns, we can determine how successful the individual advertising measures are. Our aim is to show you advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of the advertising costs incurred.

When you click on an ad served by Google, a conversion tracking cookie is activated. Cookies are small text files that your internet browser stores on your computer. These cookies usually expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page. Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the Ad-Words advertisers who have opted for conversion tracking. The advertisers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not obtain any information that can be used to personally identify users. If you do not want to participate in tracking, you can opt out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings under the keyword »User Settings«. In doing so, you will not be included in the conversion tracking statistics. We only use Google Ads based on your consent in accordance with Art. 6 (1)(a) GDPR. In the course of using Google Ads, personal data may also be transferred to the servers of Google LLC. in the USA.
You can find more information about Google's privacy policy at the following web address: https://www.google.de/policies/privacy/
If you do not want to participate in tracking, you can opt out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings or by downloading and installing the browser plug-in available under the following link: https://www.google.com/settings/ads/plugin?hl=en
Please note that certain functions of this website may not be available or may only be used to a limited extent if you have deactivated the use of cookies.
“Conversion cookies” are stored based on your consent per Art. 6 (1)(a) GDPR.

Google Tag Manager

Google Tag Manager is a solution that allows you to manage web site tags through a web interface. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users' personal data, reference is made to the following information on the Google services. Use Policy: https://www.google.com/intl/de/tagmanager/use-policy.html.

Pingdom

This website uses the Pingdom monitoring service, which is operated by Pingdom AB, Kopparbergsvägen 8, 722 13, Västerås, Sweden. Pingdom uses cookies, which are small text files that are stored locally in the cache of the site visitor's browser. These cookies are used to recognise the browser and thus enable an analysis of your access, as well as the behaviour (»performance«) and availability of our website, in order to improve the behaviour and the presentation of the contents on the website.

Insofar as personal data is also processed by individual cookies used by us, processing is carried out pursuant to Art. 6 (1) (a) GDPR based on your consent.

In order to generally deactivate the use of cookies on your computer, you can set your browser so that no more cookies can be stored on your computer in the future or that already stored cookies are deleted. However, switching off all cookies may mean that some functions on our web pages can no longer be executed. You can find Pingdom's privacy policy at https://www.pingdom.com/legal/privacy-policy/.

Retargeting

This website uses retargeting technology from releva GmbH, Feilnerstr. 10, 10969 Berlin (www.releva.nz). It allows us to address visitors of our website in a targeted manner with personalised, interest-based advertising. Ads are displayed on a cookie-based analysis of previous usage behaviour, but no personal data is stored. Retargeting technology stores a cookie on your PC or mobile device in order to collect pseudonymised data on your interests as part of a pseudonymised user profile and thus to adapt the advertising individually to the stored information. Cookies are small text files that are stored on your PC or mobile device. You will receive advertising that is highly likely to match your product and information interests. Insofar as the collected information contains a personal reference, processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our justified interest in the insertion of personalised advertising and market research. Insofar as legally required, we have obtained your consent to the processing of your data as described above in accordance with Art. 6 (1) (a) GDPR. You can revoke your given consent at any time with effect for the future. In order to exercise your right of withdrawal, please follow the procedure described in the section »Cookies« to make an objection. The information generated by the cookie in the pseudonymous user profile is not used to personally identify the visitor of the website and is not merged with personal data about the bearer of the pseudonym. Further information and the privacy policy regarding advertising and releva GmbH can be found here: https://releva.nz/datenschutz.

etracker

We use the services of etracker GmbH (Erste Brunnenstraße 1, 20459 Hamburg, Germany) on this website to analyse usage data.

Insofar as we use analysis and optimisation cookies, we obtain your explicit consent in advance pursuant to Art. 6 (1) (a) of the GDPR. If you give us your consent, cookies will be used to enable statistical coverage analysis of this website, measurement of the success of our online marketing campaigns and test procedures, e.g. to test and optimise different versions of our online offer or its components.

We do not set cookies in »cookieless mode« as part of the use of etracker. In cookieless mode, the data processing is based on our legitimate interest pursuant to Art. 6 (1) (a) of the GDPR. Our legitimate interest is the optimisation of our online offer and our web presence. As the privacy of our visitors is important to us, data that may identify an individual person, such as the IP address, login or device identifiers, are anonymised or pseudonymised as soon as possible. No other use, combination with other data or transfer to third parties will take place.

We have concluded an order processing agreement with etracker GmbH in accordance with Art. 28 of the GDPR. The data generated with etracker is processed exclusively in Germany.

You can object to the aforementioned data processing at any time by clicking on the slider. The objection has no adverse consequences. If no slider is displayed, data collection is already prevented by other blocking measures.


For further information on data protection click Sie here.

Neo Commerce

We have integrated the guided selling service Neocom from Neo Commerce GmbH (hereinafter "Neocom"), Max-Bill-Str. 8, 80807 Munich, on our website to provide you with a digital interactive product consultation. When you start this product consultation, you can find your desired product in a quiz-like, guided process and receive a product recommendation at the end, which you can then choose to have sent to you by email.

During the consultation, Neocom collects the following browser http information: browser type and version, IP address, and browser language. Additionally, a session ID is generated and temporarily stored on your device during the browser session to provide the consultation. The purpose is to enable the correct and complete display and execution of the digital product consultation, similar to a shopping cart function. The legal basis is our legitimate interest according to Art. 6 para. 1 sentence 1 lit. f GDPR (browser inquiry) and Art. 6 para. 1 sentence 1 lit. a GDPR (consent regarding the session ID).

Furthermore, a persistent Neocom session ID is stored. This is a purchase tracking tool that allows us to track whether a purchase is made following the product consultation, even across multiple browser sessions. However, this is only done with your prior consent. The legal basis for this is Art. 6 para. 1 sentence 1 lit. a GDPR. The session ID will be deleted after 365 days at the latest.

If you wish to receive the product recommendation via email, your email address will be requested. This will only be used by Neocom for the purpose of sending the requested recommendation. However, this is only done with your prior consent. The legal basis for this is Art. 6 para. 1 sentence 1 lit. a GDPR. We use the so-called "double opt-in" process for registration. After providing your email, you will receive an email from us with a link to confirm your request for the product recommendation. If you click on this confirmation link, your email will be stored for the purpose of sending the email. If you do not click on the confirmation link within 24 hours, your registration data will be blocked. You can revoke your consent to the processing of personal data at any time according to Art. 6 para. 1 sentence 1 lit. a GDPR.

Neocom uses other services for the product consultation. You can find details on these here.

Hotjar

We use Hotjar to better understand the needs of our users and optimize the services and experience on this website. With the help of Hotjar's technology, we gain a better understanding of our users' experiences (e.g., how much time users spend on which pages, which links they click, what they like and dislike, etc.), which helps us tailor our offerings based on user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices, particularly the IP address of the device (captured and stored only in anonymized form during website usage), screen size, device type (unique device identifiers), information about the browser used, location (country only), and preferred language for displaying our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually prohibited from selling the data collected on our behalf.

For more information, please see the section 'about Hotjar' on Hotjar's Help Page

VWO – Digital Experience Optimization

This website uses the web analytics service VWO from Wingify. Wingify Software Pvt. Ltd. is an Indian company headquartered in India (KLJ TOWER, 1104, North, Netaji Subhash Place, Pitam Pura, Delhi, 110034) with a German subsidiary in Hamburg (Wingify Software Pvt. Ltd., Heidenkampsweg 58, Hamburg, 20097, Germany, Email: support@vwo.com, Web: https://vwo.com, Phone: +1 415-349-0105).

With VWO, it is possible to track movements on the websites where VWO is used (so-called heatmaps). For example, it can show how far users scroll, which buttons are clicked how often, and how much time users spend on which pages.

Additionally, with VWO it is also possible to collect feedback directly from website users using a survey tool.

We use VWO's technology to better understand the needs of our users and to optimize the offerings and experience on our website.

In this context, we process the following data, among others:

• Which buttons are clicked
• Mouse movement trajectory
• How far is scrolled
• IP address of the device
• Screen size of a device
• Device type (Unique Device Identifiers) and browser information
• Geographical location (country only)
• The preferred language in which our website is displayed

Of course, when using this tool, we particularly pay attention to the protection of your personal data. The use of our website is analyzed completely anonymously via VWO, all personal data is automatically hidden and not processed. Areas of the website where personal data of you or third parties are displayed are automatically hidden by VWO and are therefore not traceable at any time. To exclude direct personal reference, IP addresses are only stored and processed in anonymized form.

VWO uses cookies and other technologies to collect data on user behavior and their devices. VWO stores this information in a pseudonymized user profile on our behalf. VWO is contractually prohibited from sharing the data collected on our behalf.

The legal basis for the processing of your personal data is Art. 6 para. 1 lit. a GDPR (consent).

You can prevent the processing of your personal data by VWO at any time by not giving us consent to use “behavioral cookies” on this website or by withdrawing this consent with effect for the future.

Alternatively, you can generally prevent the collection of your data by VWO by disabling the tool via the VWO opt-out page: https://vwo.com/opt-out/

For more information about Wingify Software Pvt. Ltd. and the VWO tool, please visit: https://vwo.com/

You can find Wingify Software Pvt. Ltd.'s privacy policy at: https://vwo.com/privacy-policy/

Microsoft Clarity – Free Heatmaps and Session Recordings

We use Microsoft Clarity on our website, a service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA.

“Microsoft Clarity” is a process by Microsoft that uses a pseudonymous user ID to conduct analysis, such as evaluating performance data for certain designs and mouse movements on the website. The analyzed data is intended to provide you with personalized and interest-based advertising based on the created user profile, as well as to perform conversion and reach measurement.

The settings of Clarity are configured so that the data collection by Microsoft is already done in pseudonymized form via so-called IP masking. The data processing is based on your consent according to Art. 6 para. 1 a) GDPR.

The following data is processed in pseudonymized form:

• Usage data (visited page, time of access)
• Device information
• IP address
• Location data
• Movement data (mouse and scroll movements)

As Microsoft may transfer personal data to affiliated companies and subcontractors in countries outside the EU and the EEA, further protective mechanisms are required to ensure the data protection level of the GDPR. There is an adequacy decision of the EU Commission according to Art. 45 para. 1 GDPR regarding companies certified under the EU-U.S. Data Privacy Framework for the USA. Microsoft Corporation is certified under the EU-U.S. Data Privacy Framework and is therefore committed to complying with appropriate data protection standards, which can be viewed at the following link: https://www.dataprivacyframework.gov/s/participant-search.

For potential transfers to other third countries outside the EU and the EEA, where there is no adequacy decision of the EU Commission, we have also agreed on standard data protection clauses according to Art. 46 para. 2 lit. c GDPR with the provider. These oblige the recipient of the data in the third country to process the data according to the level of protection in Europe.

For more information on data protection and the cookies used by Microsoft, please visit Microsoft's website at: https://privacy.microsoft.com/en-us/privacystatement

7. Advertising / Newsletter

Newsletter data

To subscribe to our newsletter, you must provide your e-mail address. We also require proof that you are actually the owner of this email address and that you agree to receive the newsletter (double opt-in).
In the first step, you will receive an e-mail with a link that you can use to confirm that you, as the owner of the corresponding e-mail address, wish to receive newsletters in future. By confirming, you give us your consent in accordance with Art. 6 para. 1 lit. a GDPR that we may use your personal data for the purpose of sending the desired newsletter. When you register for the newsletter, in addition to the e-mail address required for sending the newsletter, we store the IP address you used to register for the newsletter as well as the date and time of registration and confirmation in order to be able to trace possible misuse at a later date.
The processing of your data is based on your express consent in accordance with the GDPR, which can be revoked at any time without affecting the legality of the processing carried out until revocation.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after you unsubscribe from the newsletter. Data stored by us for other purposes (e.g. e-mail addresses for the customer area) remain unaffected by this.
The newsletter is delivered using specialized service providers for newsletter delivery, which are explained in more detail below. Your data will not be passed on to third parties beyond this.
We have concluded an order processing contract with both service-providers in accordance with Art. 28 GDPR.

Brevo

We use the Brevo service from Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany, to send the newsletters we offer. Brevo makes it possible to organize and analyze the newsletter dispatch in detail. The data provided to subscribe to the newsletter is stored on Brevo servers in Germany.

Brevo helps us to evaluate the effectiveness of our newsletter campaigns. For example, we can track whether newsletter messages have been opened and which links may have been clicked on. This enables us to recognise which content is of particular interest to our subscribers. You can revoke your consent to the storage of your data and email address and their use for sending the newsletter at any time, for example via the "unsubscribe" link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the cancellation.

The data stored for the newsletter subscription will be stored by us or the newsletter service until you unsubscribe and will be removed from the distribution list after you unsubscribe.

Further information on data protection at Brevo can be found at: https://www.brevo.com/de/legal/privacypolicy/.

Upon request, we will inform you free of charge which data we have stored about you. You have the right to request the correction, blocking or deletion of your data.

8. Payment service providers

PayPal

In the case of payment via PayPal, credit card via PayPal, direct debit via PayPal or – if offered – »purchase on account« or »payment by instalments« via PayPal, we will pass on your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter »PayPal«) as part of the payment process. The data you provide will be supplied to PayPal based on Art. 6 (1) (a) GDPR and only to the extent necessary for payment processing.
PayPal reserves the right to carry out a credit check for the payment methods »credit card via Pay-Pal«, »direct debit via PayPal« or – if offered – »purchase on account« or »payment by instalments« via PayPal. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 (1) (f) GDPR on the basis of PayPal's legitimate interest in determining your solvency. PayPal uses the result of the credit assessment with regard to the statistical probability of non-payment for the purpose of deciding whether to provide the respective payment method. The credit report may contain probability values (»score values«). Insofar as score values are included in the result of the credit report, they are based on a scientifically recognised mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. For further information on data protection, including the credit agencies used, please refer to Pay-Pal's privacy policy:
https://www.paypal.com/us/webapps/mpp/ua/privacy-full
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.

ConCardis

On our website we also offer the option to pay by credit card. The provider of this payment service is ConCardis GmbH, Helfmann-Park 7, 65760 Eschborn, Germany (hereinafter referred to as »ConCardis«), to whom we pass on the information you provide during the ordering process together with the information about your order in accordance with Art. 6 (1) (b) GDPR. Your data will be passed on exclusively for the purpose of payment processing with the payment service provider ConCardis and only to the extent necessary for this purpose. You can obtain further information on ConCardis' data protection provisions at the following Internet address: https://www.concardis.com/de-en/protecting-your-data.

SOFORT transfer

If you select the payment method »SOFORT«, the payment will be processed by the payment service provider SOFORT GmbH, Theresienhöhe 12, 80339 Munich, Germany (hereinafter »SOFORT«), to whom we will pass on the information you provided during the ordering process together with the information about your order in accordance with Art. 6 (1) (b) GDPR. Sofort GmbH is part of the Klarna Group (Klarna Bank AB (publ), Sveavägen 46, 11134 Stockholm, Sweden). Your data is transferred exclusively for the purpose of payment processing with the payment service provider SOFORT and only insofar as it is necessary for this purpose. The following website provides further information about the data protection regulations of SOFORT: https://www.klarna.com/sofort/datenschutz.

9. Application for job vacancies by e-mail

On our website we advertise currently vacant positions in a separate section, for which interested parties can apply by e-mail to the contact address provided.
In order to be included in the application process, applicants must provide us in their application by e-mail with all personal data required for a thorough and informed assessment and selection.
The information required includes general personal information (name, address, telephone or electronic contact details) and evidence of the qualifications required for the job. Where appropriate, it may also be necessary to include health-related information which, in the interests of social protection, must be given special consideration with respect to the applicant under labour and social law.
The elements which an individual application must contain for it to be considered and in what form these elements are to be sent by e-mail can be found in the respective job advertisement.
After receipt of the application sent to the e-mail contact address provided, the applicant data will be stored by us and evaluated exclusively for the purpose of processing the application. For any queries arising in the course of processing, we will use at our discretion either the e-mail address provided by the applicant with his or her application or a telephone number provided.
The legal basis for these processing operations, including contact for further inquiries, is in principle Art. 6 (1) (b) GDPR in conjunction with § 26 (1) BDSG, according to which the completion of the application procedure is considered to be the initiation of an employment contract. Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data such as information on the status of severely disabled persons) are requested from applicants in the course of the application procedure, processing is carried out in accordance with Art. 9 (2) (b) GDPR so that we can exercise the rights arising from labour law and social security and social protection law and fulfil our obligations in this respect.
Cumulatively or alternatively, the processing of the special categories of data may also be based on Art. 9 (1) (h) GDPR if it is carried out for the purposes of health care or for assessing the applicant's ability to work. If, in the course of the evaluation described above, the applicant is not selected or withdraws his or her application prematurely, his or her data transmitted by e-mail and all electronic correspondence, including the original application e-mail, will be deleted after 6 months at the latest following notification. This period is based on our legitimate interest in being able to answer any follow-up questions about the application and, if necessary, to comply with our obligations to provide evidence under the regulations on the equal treatment of applicants.
In the event of a successful application, the data provided will be processed on the basis of Art. 6 (1) (b) GDPR in conjunction with § 26 para. 1 BDSG for the purposes of the employment relationship.

10. Rights of the data subject

The applicable data protection law grants you comprehensive data subject rights (rights of information and intervention) vis-à-vis the person responsible for processing your personal data, about which we inform you below:

Right to information in accordance with Art. 15 GDPR: In particular, you have the right to be informed about your personal data processed by us, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right of rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it has not been collected from you by us, the existence of automated decision making including profiling and, if applicable, meaningful information on the logic involved and the scope and intended effects of such processing on you, as well as your right to be informed of the guarantees provided under Art. 46 GDPR when your data is transferred to third countries;
Right to rectification under Art. 16 GDPR: You have a right to immediate correction of incorrect data concerning you and/or completion of your incomplete data stored with us;
Right to erasure in accordance with Art. 17 GDPR: You have the right to request the deletion of your personal data if the requirements of Art. 17 para. 1 GDPR are met. However, this right does not apply in particular if the processing is necessary for the exercise of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;
Right to restrict processing in accordance with Art. 18 GDPR: You have the right to demand the restriction of the processing of your personal data as long as the accuracy of your data which you dispute is checked, if you refuse to have your data deleted due to unlawful data processing and demand instead the restriction of the processing of your data, if you require your data for the assertion, exercise or defence of legal claims, after we no longer require these data after the purpose has been achieved, or if you have lodged an objection for reasons of your particular situation, as long as it has not yet been established whether our justified reasons outweigh the objection;
Right to information in accordance with Art. 19 GDPR: If you have asserted the right to rectify, erase or limit the processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, erasure or limitation of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
Right to data transferability according to Art. 20 GDPR: You have the right to receive your personal data that you have provided us with in a structured, common and machine-readable format or to request that it be transferred to another responsible party, insofar as this is technically feasible;
Right to revoke consents granted under Art. 7 (3) GDPR: You have the right to revoke your consent to the processing of data at any time with effect for the future. In the event of revocation, we will immediately delete the data concerned, unless further processing cannot be based on a legal basis for processing without consent. Revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until revocation;
Right of appeal under Art. 77 GDPR: If you believe that the processing of personal data relating to you is in breach of GDPR, you have the right – without prejudice to any other administrative or judicial remedy – to lodge a complaint with a supervisory authority, in particular in the Member State in which you are resident, your place of work is located or the place where the alleged breach occurs.

RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST IN THE CONTEXT OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR SPECIAL SITUATION, WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS FOR PROCESSING WORTHY OF PROTECTION WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS. IF YOUR PERSONAL DATA IS PROCESSED BY US FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING. YOU MAY EXERCISE THE RIGHT TO OBJECT AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

11. Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if relevant – additionally by the respective legal retention period (e.g. retention periods under commercial and tax law).
When personal data are processed on the basis of an express consent in accordance with Art. 6 (1) (a) GDPR, these data are stored until the person concerned revokes his or her consent.
If there are legal retention periods for data which are processed within the framework of legal or similar obligations based on Art. 6 (1) (b) GDPR, these data are routinely deleted after the retention periods have expired, provided that they are no longer required for the fulfilment or initiation of a contract and/or we have no justified interest in their further storage.
When personal data are processed on the basis of Art. 6 (1) (f) GDPR, these data are stored until the person concerned exercises his or her right to object in accordance with Art. 21 (1) GDPR, unless we can prove compelling reasons for processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves to assert, exercise or defend legal claims.
When personal data are processed for the purpose of direct advertising on the basis of Art. 6 (1) (f) GDPR, these data are stored until the person concerned exercises his or her right of objection under Art. 21 (2) GDPR.
Moreover, unless otherwise stated in the other information in this statement on specific processing situations, stored personal data will be deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.