Privacy Policy
Privacy Policy
1. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on data protection, please refer to our Privacy Policy, which is listed below this text.
Data Collection on This Website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact information in the “Information on the Data Controller” section of this Privacy Policy.
How do we collect your data?
Your data is collected, in part, when you provide it to us. This may include, for example, data that you enter into a contact form.
Other data is collected by our IT systems automatically or with your consent when you visit the website. These are primarily technical data (e.g., web browser, operating system, or the time the page was accessed). This data is collected automatically as soon as you visit this website.
What do we use your data for?
Some of the data is collected to ensure that the website functions properly. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive, free of charge, information about the source, recipients, and purpose of your stored personal data. You also have the right to request that this data be corrected or deleted. If you have given your consent to data processing, you may withdraw that consent at any time, effective for the future. In addition, you have the right to request that the processing of your personal data be restricted under certain circumstances. In addition, you have the right to file a complaint with the relevant supervisory authority.
Please feel free to contact us at any time regarding this matter or any other questions you may have about data protection.
2. Hosting
We host our website’s content with the following provider:
Hetzner
The provider is Hetzner Online GmbH, Industriestr. 25, 91710
Gunzenhausen (hereinafter referred to as Hetzner).
For more details, please refer to Hetzner’s Privacy Policy:
https://www.hetzner.com/de/rechtliches/datenschutz
The use of Hetzner is based on Art. 6, para. 1(a). Article f of the GDPR. We have a legitimate interest in ensuring that our website is as reliable as possible. If consent has been obtained, processing is carried out exclusively on the basis of Article 6, paragraph 1(a). a GDPR and § 25, para. 1 TDDDG, to the extent that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent may be revoked at any time.
Order Processing
We have entered into a Data Processing Agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law that ensures the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
Cloudflare
We use the “Cloudflare” service. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).
Cloudflare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through the Cloudflare network. This enables Cloudflare to analyze the traffic between your browser and our website and act as a filter between our servers and potentially malicious traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies to recognize Internet users; however, these are used solely for the purpose described here.
Our use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6(1)(f) of the GDPR).
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. For details and more information on security and data protection at Cloudflare, click here: https://www.cloudflare.com/privacypolicy/.
The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information on this, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/5666.
Order Processing
We have entered into a Data Processing Agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law that ensures the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
3. General Information and Mandatory Disclosures
Privacy Policy
The operators of this website take the protection of your personal information very seriously. We treat your personal data confidentially and in accordance with applicable data protection laws and this Privacy Policy.
When you use this website, various types of personal data are collected. Personal data is data that can be used to identify you personally. This Privacy Policy explains what information we collect and how we use it. It also explains how and for what purpose this is done.
Please note that data transmission over the Internet (e.g., when communicating via email) may be subject to security vulnerabilities. It is not possible to completely protect data from access by third parties.
Note Regarding the Responsible Party
The entity responsible for data processing on this website is:
SR Travel GmbH & Co KG
170 Gruenberger Street
35394 Giessen
Phone: +49(0)641 972 59 – 0
E-Mail: contact@sr-travel.de
Head office: Rödgener Str. 12, D-35394 Giessen
The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g., names, email addresses, etc.).
Retention period
Unless a more specific retention period is stated in this Privacy Policy, we will retain your personal data until the purpose for which it was collected no longer applies. If you submit a valid request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible grounds for storing your personal data (e.g., B. Tax or commercial law
Retention periods); in the latter case, the data will be deleted once these grounds no longer apply.
General Information on the Legal Basis for Data Processing
on this website
If you have consented to the processing of your data, we process your personal data pursuant to Art. 6, para. 1(a). a GDPR, specifically Art. 9, para. 2 lit. a GDPR, provided that special categories of data are covered under Art. 9, para. 1 GDPR. In the event of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49, para. 1(a). a GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g., via device fingerprinting), data processing is additionally based on Section 25, para. 1 TDDDG. Consent may be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of precontractual measures, we process your data on the basis of Article 6(
1(a). Article 6 of the GDPR. Furthermore, we process your data to the extent that it is necessary to comply with a legal obligation, pursuant to Article 6( 1(a). c GDPR. Data processing may also be based on our legitimate interest pursuant to Article 6( 1(a). in accordance with Article f of the GDPR. The following sections of this Privacy Policy provide information about the legal basis applicable in each specific case.
Data Protection Officer
We have appointed a data protection officer.
Mprotect365 GmbH
17-21 Nordstraße
04105 Leipzig
Phone: +49(0)641 972 59 – 0
Email: datenschutz@sr-travel.de
Notice regarding the transfer of data to third countries that do not meet data protection standards, as well as the transfer of data to U.S. companies that are not DPF-certified.
Among other things, we use tools from companies based in third countries that do not meet data protection standards, as well as U.S. tools whose providers are not certified under the EU-U.S. Data Privacy Framework (DPF). If these tools are active, your personal data may be transferred to these countries and processed there. Please note that in third countries where data protection standards are inadequate, a level of data protection comparable to that of the EU cannot be guaranteed.
We would like to point out that the United States, as a safe third country, generally maintains a level of data protection comparable to that of the EU. Accordingly, data transfers to the United States are permitted if the recipient is certified under the “EU-U.S. Data Privacy Framework” (DPF) or has appropriate additional safeguards in place. Information regarding transfers to third countries, including the recipients of the data, can be found in this Privacy Policy.
Recipients of Personal Data
As part of our business operations, we collaborate with various external parties. In some cases, this requires the transfer of personal data to these external parties. We disclose personal data to external parties only if this is necessary for the performance of a contract, if we are legally required to do so (e.g., disclosure of data to tax authorities), or if we have a legitimate interest pursuant to Article 6(1)
lit. under the GDPR, or if another legal basis permits the transfer of data. When using
We disclose our customers’ personal data to data processors only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is entered into.
Withdrawal of Your Consent to Data Processing
Many data processing operations are only possible with your explicit consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out up to the time of revocation remains unaffected by the revocation.
Right to Object to Data Collection in Specific Cases
as well as against direct marketing (Art. 21 of the GDPR)
If data processing is based on Art. 6, para. 1(a). If the processing is carried out pursuant to Article 18(e) or (f) of the GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. You can find the specific legal basis on which processing is based in this Privacy Policy. If you object, we will no longer process your personal data in question, unless we can demonstrate compelling legitimate grounds for the processing
demonstrate that there are grounds that override your interests, rights, and freedoms, or that the processing is necessary for the establishment, exercise, or defense of legal claims (objection under Article 21(1) of the GDPR).
If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing. If you object, your personal data will no longer be used for direct marketing purposes (objection pursuant to Article 21(2) of the GDPR).
Right to File a Complaint with the Competent Regulatory Authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the location of the alleged violation. The right to appeal is without prejudice to any other administrative or judicial remedies.
Right to Data Portability
You have the right to have data that we process automatically—based on your consent or to fulfill a contract—provided to you or to a third party in a commonly used, machine-readable format. If you request that your data be transferred directly to another data controller, this will be done only to the extent that it is technically feasible.
Access, Correction, and Deletion
Subject to applicable legal provisions, you have the right at any time to receive, free of charge, information about your stored personal data, its origin, and its recipients, as well as the purpose of the data processing, and, where applicable, the right to have this data corrected or deleted. If you have any questions about this or other matters related to personal data, please feel free to contact us at any time.
Right to Restriction of Processing
You have the right to request that the processing of your personal data be restricted. Please feel free to contact us at any time regarding this matter. The right to restrict processing applies in the following cases:
- If you dispute the accuracy of your personal data stored with us, we generally need
it’s time to check this out. For the duration of the review, you have the right to request that the processing of your personal data be restricted. - If the processing of your personal data was or is unlawful, you may, instead of requesting erasure,
request that data processing be restricted. - If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request that the processing of your personal data be restricted instead of being erased.
- If you file an objection under Art. 21, para. If you have filed a complaint under Article 1 of the GDPR, a balancing of your interests against ours must be conducted. As long as it remains unclear whose interests take precedence, you have the right to request that the processing of your personal data be restricted.
If you have restricted the processing of your personal data, such data—apart from its storage—may be processed only with your consent or for the purpose of asserting, exercise, or defense of legal claims; to protect the rights of another natural or legal person; or for reasons of a substantial public interest of the European Union or a Member State.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential information—such as orders or inquiries that you send to us as the website operator—this site uses SSL or TLS encryption. You can tell that a connection is encrypted when the browser’s address bar changes from “http://” to “https://” and when you see the padlock icon in your browser’s address bar.
If SSL or TLS encryption is enabled, the data you send to us cannot be read by third parties.
Encrypted Payments on This Website
If, after entering into a paid contract, you are required to provide us with your payment information (such as B. Account number at
direct debit authorization), this information is required to process the payment.
Payment transactions using standard payment methods (Visa/MasterCard, direct debit) are processed exclusively via an encrypted SSL or TLS connection. You can tell that a connection is encrypted when the browser’s address bar changes from “http://” to “https://” and when you see the padlock icon in your browser’s address bar.
With encrypted communication, the payment information you send to us cannot be read by third parties.
Objection to Promotional Emails
We hereby object to the use of contact information published in accordance with the legal requirement to provide a site notice for the purpose of sending unsolicited advertising and informational materials. The operators of this website expressly reserve the right to take legal action in the event of unsolicited promotional communications, such as spam emails.
4. Data Collection on This Website
Cookies
Our website uses what are known as “cookies.” Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or they are automatically deleted by your
Web browser.
Cookies may be set by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain third-party services into websites (e.g., cookies used to process payment services).
Cookies serve various purposes. Many cookies are technically necessary because certain website features would not work without them (e.g., the shopping cart feature or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are used to carry out the electronic communication process and to provide certain services requested by you
If cookies are required for certain desired functions (e.g., the shopping cart feature) or to optimize the website (e.g., cookies used to measure website traffic) (essential cookies), they are used on the basis of Art. 6( 1(a). stored in accordance with Article 6 of the GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to ensure that its services are provided in a technically flawless and optimized manner. Provided that consent has been given to
If consent has been requested for the storage of cookies and similar tracking technologies, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent may be withdrawn at any time.
You can configure your browser to notify you when cookies are set, to allow cookies only on a case-by-case basis, to block cookies in specific cases or generally, and to enable the automatic deletion of cookies when you close your browser. If you disable cookies, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this Privacy Policy.
Server Log Files
The provider of this website automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the connecting computer
- Time of the server request
- IP address
This data is not combined with data from other sources.
This data is collected pursuant to Article 6, paragraph 1(a). Article f of the GDPR. The website operator has a legitimate interest in ensuring that the website functions properly and is optimized—to this end, server log files must be collected.
Inquiries by email, phone, or fax
If you contact us by email, phone, or fax, your inquiry—including all personal data contained therein (name, inquiry)—will be stored and processed by us for the purpose of handling your request. We will not share this information without your consent.
This data is processed on the basis of Article 6, paragraph 1(a). Article 6(b) of the GDPR, provided that your request is related to the performance of a contract or is necessary for the implementation of precontractual measures. In all other cases, the processing is based on our legitimate interest in effectively handling inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), provided that consent was requested; you may withdraw your consent at any time.
The data you send us via contact requests will remain with us until you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions—in particular statutory retention periods—remain unaffected.
5. Analytics Tools and Advertising
Matomo
This website uses the open-source web analytics service Matomo.
With the help of Matomo, we are able to collect and analyze data on how visitors use our website. This allows us, among other things, to determine when specific pages were viewed and from which region the visits originated. In addition, we collect various log files (e.g., IP address, referrer, browsers and operating systems used) and can track whether our website visitors perform certain actions (e.g., clicks, purchases, etc.).
The use of this analytics tool is based on Article 6, paragraph 1(a). Article f of the GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If consent has been obtained, processing is carried out exclusively on the basis of Article 6, paragraph 1(a). a GDPR and § 25, para. 1 TDDDG, to the extent that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent may be revoked at any time.
IP Anonymization
We use IP anonymization for our Matomo analytics. In this process, your IP address is truncated before analysis, so that it can no longer be uniquely associated with you.
Cookie-Free Analytics
We have configured Matomo so that it does not store cookies in your browser.
Hosting
We host Matomo exclusively on our own servers, so all analytics data remains with us and is not shared with third parties.
You have the option to prevent the actions you take here from being analyzed and linked. This will protect your privacy, but it will also prevent the owner from learning from your actions and improving the user experience for you and other users.
Dealfront
Our website uses technologies provided by Dealfront (Dealfront Finland Oy, part of Dealfront Group GmbH) to analyze visitor behavior. During this process, a visitor’s IP address is processed. In this process, the IP address is processed to help us understand which companies (B2B) visit our website. As part of the processing, the IP address is enriched with related information, such as the company name or industry code. To this end, at the start of the session, the website visitor’s IP address and the corresponding session data are compared against a comprehensive whitelist of known companies.
As part of this processing, Dealfront uses so-called first-party cookies to analyze visitor behavior.
To the extent that we process personal data in this context, we do so on the basis of our legitimate interest (Art. 6 (1) (a) (Article 6(f) of the GDPR) to improve our products, services, sales, and marketing. To prevent this processing, website visitors can install and configure appropriate ad blockers or use No-Script plugins in their browser. The data will be deleted as soon as it is no longer needed for the intended purposes. However, statutory retention requirements may, in some cases, result in a longer retention period for the data in question. We have entered into a data processing agreement with Dealfront to ensure compliance with applicable data protection standards.
6. Plugins and Tools
Google Fonts (local hosting)
This site uses Google Fonts, provided by Google, to ensure consistent font display. Google Fonts are installed locally. No connection is made to Google’s servers during this process.
For more information about Google Fonts, visit
https://developers.google.com/fonts/faq
and in Google’s Privacy Policy:
https://policies.google.com/privacy?hl=de
.
Adobe Fonts
This website uses Adobe web fonts to ensure consistent display of certain fonts. The provider is Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe).
When you visit this website, your browser downloads the necessary fonts directly from Adobe so that they can be displayed correctly on your device. When you do this, your browser establishes a connection to Adobe’s servers in the United States. This allows Adobe to determine that this website was accessed via your IP address. According to Adobe, no cookies are stored when the fonts are delivered.
The storage and analysis of the data are based on Art. 6, para. 1(a). Article f of the GDPR. The website operator has a legitimate interest in ensuring a consistent typographic style on its website. If consent has been obtained, processing is carried out exclusively on the basis of Article 6, paragraph 1(a). a GDPR and § 25, para. 1 TDDDG, to the extent that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent may be revoked at any time.
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. You can find details here: https://www.adobe.com/de/privacy/eudatatransfers.html.
For more information about Adobe Fonts, visit: https://www.adobe.com/de/privacy/policies/adobe-fonts.html.
Die Datenschutzerklärung von Adobe finden Sie unter: https://www.adobe.com/de/privacy/policy.html
The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF commits to complying with these data protection standards. For more information on this, please visit the provider’s website at the following link: https://www.dataprivacyframework.gov/participant/5660.
Font Awesome (local hosting)
This site uses Font Awesome to ensure consistent font styling. Font Awesome is installed locally. A connection to servers operated by Fonticons, Inc. does not take place in this context.
For more information about Font Awesome, please see the Font Awesome Privacy Policy at:
https://fontawesome.com/privacy
.
Wordfence
We have integrated Wordfence into this website. The provider is Defiant Inc., Defiant, Inc., 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).
Wordfence is used to protect our website from unauthorized access or malicious cyberattacks. To this end, our website establishes a persistent connection to Wordfence’s servers so that Wordfence can compare the access attempts made on our website against its databases and block them if necessary.
The use of Wordfence is based on Art. 6, para. 1(a). Article f of the GDPR. The website operator has a legitimate interest in protecting its website as effectively as possible against cyberattacks. If consent has been obtained, processing is carried out exclusively on the basis of Article 6, paragraph 1(a). a GDPR and § 25, para. 1 TDDDG, to the extent that the consent covers the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by the TDDDG. Consent may be revoked at any time.
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. You can find details here: https://www.wordfence.com/help/general-data-protection-regulation/.
Order Processing
We have entered into a Data Processing Agreement (DPA) for the use of the service mentioned above. This is a contract required under data protection law that ensures the service provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
7. E-commerce and Payment Providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data to establish, define the terms of, and modify our contractual relationships. We collect, process, and use personal data regarding the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill the user. The legal basis for this is Art. 6, para. 1(a). Article 6 of the GDPR.
The customer data collected will be deleted upon completion of the order or termination of the business relationship and after any applicable statutory retention periods have expired. Statutory retention periods remain unaffected.
Data Transmission Upon Contract Formation for Online Stores and Retailers
and shipping
When you order goods from us, we share your personal data with the shipping company responsible for delivery and with the payment service provider responsible for processing your payment. Only data that the respective service provider needs to perform its duties will be disclosed. The legal basis for this is Art. 6, para. 1(a). Article 6(b) of the GDPR, which permits the processing of data for the purpose of performing a contract or taking steps prior to entering into a contract.
Provided that you have given the appropriate consent pursuant to Art. 6, para. 1(a). If you have given your consent under the GDPR, we will share your email address with the shipping company responsible for delivering your order so that it can notify you via email about the shipping status of your order; you may revoke your consent at any time.
Data Transfer Upon Conclusion of a Contract for Services and
digital content
We disclose personal data to third parties only when necessary for the fulfillment of the contract, such as to the financial institution responsible for processing payments.
The data will not be disclosed to third parties, or will only be disclosed if you have expressly consented to such disclosure. We will not disclose your data to third parties without your express consent, for example for advertising purposes.
The legal basis for data processing is Article 6, paragraph 1(a). Article 6(b) of the GDPR, which permits the processing of data for the purpose of performing a contract or taking steps prior to entering into a contract.
Payment Services
We integrate third-party payment services into our website. When you make a purchase from us, your payment information (e.g., name, payment amount, bank account information, credit card number) is processed by the payment service provider for the purpose of processing the payment.
The respective terms and conditions and privacy policies of the relevant providers apply to these transactions. The use of the
Payment service providers operate on the basis of Art. 6, para. 1(a). b) GDPR (contract performance) and to ensure that the payment process is as smooth, convenient, and secure as possible (Art. 6(1)(f) GDPR). To the extent that your consent is requested for certain actions, Art. 6, para. 1(a). a. The legal basis for data processing under the GDPR; consent may be revoked at any time with future effect.
We use the following payment services / payment service providers on this website:
PayPal
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).
Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. You can find details here:
https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full
.
For more details, please refer to PayPal’s Privacy Policy:
https://www.paypal.com/de/webapps/mpp/ua/privacy-full
.
Mastercard
The provider of this payment service is Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium (hereinafter “Mastercard”).
Mastercard may transfer data to its parent company in the United States. Data transfers to the United States are subject to the Binding
Based on Mastercard’s Corporate Rules. You can find details here:
https://www.mastercard.de/de-de/datenschutz.html
and
https://www.mastercard.us/content/dam/mccom/global/documents/mastercard-bcrs.pdf
.
VISA
This payment service is provided by Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, United Kingdom (hereinafter “VISA”).
The United Kingdom is considered a safe third country with regard to data protection. This means that the United Kingdom has a level of data protection that is equivalent to that of the European Union.
VISA may transfer data to its parent company in the United States. Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses. You can find details here:
https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zu-zustandigkeitsfragen-fur-den-ewr.html
.
For more information, please refer to VISA’s Privacy Policy:
https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html
.
8. Our Own Services
Handling of Applicant Data
We offer you the opportunity to apply for a position with us (e.g., by email, mail, or through our online application form). Below, we provide information about the scope, purpose, and use of your personal data collected as part of the application process. We assure you that the collection, processing, and use of your data are carried out in accordance with applicable data protection laws and all other legal requirements, and that your data will be treated with the strictest confidentiality.
Scope and Purpose of Data Collection
If you submit an application to us, we will process your related personal data (e.g., contact and communication information, application materials, notes taken during job interviews, etc.) to the extent necessary to make a decision regarding the establishment of an employment relationship. The legal basis for this is Section 26 of the German Federal Data Protection Act (BDSG) (initiation of an employment relationship) and Article 6( 1(a). b GDPR (general pre-contractual processing) and—if you have provided consent—Art. 6( 1(a). a GDPR. Consent may be revoked at any time. Your personal data will be shared within our company exclusively with those individuals involved in processing your application.
If your application is successful, the data you submitted will be processed in accordance with § 26 of the German Federal Data Protection Act (BDSG) and Art. 6( 1(a). b) GDPR for the purpose of carrying out the employment relationship in our data processing systems.
Data Retention Period
If we are unable to offer you a position, if you decline a job offer, or if you withdraw your application, we reserve the right to retain the data you have provided, based on our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted, and the physical application documents will be destroyed.
The information is retained primarily for evidentiary purposes in the event of a legal dispute. If it is apparent that the data will be needed after the 6-month period has expired (e.g., due to an impending or pending legal dispute), the data will not be deleted until the purpose for its continued retention no longer applies.
Data may also be retained for a longer period if you have provided the appropriate consent (Art. 6(1)(a) of the GDPR) or if statutory retention requirements prevent its deletion.
Inclusion in the Candidate Pool
If we do not offer you a position, we may be able to add you to our candidate pool. If you are accepted, all documents and information from your application will be added to the applicant pool so that we can contact you if suitable openings arise.
Inclusion in the candidate pool is based solely on your express consent (Art. Section 6, para. 1(a). a
(GDPR). Providing consent is voluntary and has no bearing on the ongoing application process.
The data subject may withdraw their consent at any time.
In this case, the data will be permanently deleted from the applicant pool, unless there are legal grounds for retaining it.
Data from the applicant pool will be permanently deleted no later than two years after consent is granted.
9. Newsletter
9.1 Registration and Double Opt-In
When you subscribe to our newsletter, we process the data you provide in the registration form (email address, optional name/club). Registration is done via the double-opt-in process: Your email address will be activated only after you confirm the registration email. We log the time of registration and confirmation, as well as the IP address used during the process. The legal basis is your consent pursuant to Art. 6(1)(a) of the GDPR.
9.2 Shipping and Performance Tracking with Brevo
Mailings are handled by Brevo (Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin). The data is stored on Brevo servers in Germany. For statistical analysis, our newsletters contain a tracking pixel that measures the number of times they are opened and the number of link clicks. This performance measurement is conducted only with your consent (Art. 6(1)(a) GDPR in conjunction with § 25(1) TDDDG).
9.3 Transfers to Third Countries
Brevo uses subcontractors in the United States for certain technical functions (e.g., Cloudflare, Inc., Datadog, Inc.). These are certified under the EU–U.S. Data Privacy Framework or protected by standard contractual clauses in accordance with Article 46(2)(c) of the GDPR.
9.4 Retention Period / Deletion
Your data will remain stored as long as your subscription is active. After unsubscribing, you will be removed from the mailing list and added to a block list to prevent future mailings (Art. 6, para. 1, subparagraph f of the GDPR).
9.5 Cancellation
You may revoke your consent to receive newsletters and performance tracking at any time, effective for the future—by clicking the unsubscribe link in any newsletter email or by sending a message to the contact information provided above.
9.6 Rights of Data Subjects
The rights to access, rectification, erasure, restriction of processing, data portability, and the right to lodge a complaint, as described in Section 3 of this Privacy Policy, apply.
As of May 4, 2026