Data protection

Privacy Policy

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent in the context of providing the nele.ai application.

This Privacy Policy applies to all processing of personal data carried out by us, both in the context of the provision of nele.ai and in particular on the websites and functions belonging to nele.ai (hereinafter collectively referred to as the "Online Offer").

The terms used are not gender-specific.

Status: 3. January 3, 2025

Overview

Controller

GAL Digital GmbH
Unter den Linden 26
35410 Hungen-Obbornhofen
Germany

E-mail address: info@gal-digital.de

Contact Data Protection Officer

Dr. Thomas Schwenke, contact: datenschutz@gal-digital.de.

Overview of processing

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

Types of data processed

Inventory data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication and process data.
Log data.

Categories of data subjects

Service recipients and clients.
Interested parties.
Communication partners.
Users.
Business and contractual partners.
Third parties.

Purposes of processing

Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Direct marketing.
Reach measurement.
Tracking.
Business and organizational procedures.
Conversion measurement.
Target group formation.
Affiliate tracking.
Organizational and administrative procedures.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online offer and user-friendliness.
Information technology infrastructure.
Business processes and business management procedures.
Artificial intelligence (AI).

Mandatory legal bases

Mandatory legal bases according to the GDPR: The following provides you with an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and data transfer as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Mandatory legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection ("Swiss DPA" for short). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be stated and that the processing of personal data be carried out in good faith, lawfully and reasonably (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).

Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to their broader application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons;The controller shall implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, taking into account the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and responses to data breaches. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of personal data

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

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required data transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.In the context of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Swiss Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss DPA, exceptions may be made for the disclosure of data abroad if certain conditions are met, including the consent of the data subject, contract performance, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements. As part of the so-called "Data Privacy Framework" (DPF), the Swiss have recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 07.06.2024. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require the data to be stored or archived for a longer period of time.

In particular, data that must be stored for reasons of commercial or tax law or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing operations.

If there is more than one information on the retention period or deletion periods of a date, the longest period is always decisive.

If a period does not expressly begin on a specific date and lasts for at least one year, it shall automatically start at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the time limit is the time at which the termination or other termination of the legal relationship takes effect.

Data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, will only be processed for the reasons that justify its storage.

Further information on processing processes, procedures and services:

Retention and deletion of data: The following general time limits apply to retention and archiving under German law:
- 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents required for their understanding, accounting vouchers and invoices (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of the commercial or business letters sent, other documents, insofar as they are relevant for taxation, e.g. time sheets, operating documents and other documents. e.g. hourly wage slips, company accounting sheets, calculation documents, price markings, but also payroll accounting documents, insofar as they are not already accounting documents and cash register strips (§ 147 para. 3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
- 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on previous business transactions;
Storage and deletion of data: The following general periods apply to storage and archiving in accordance with Swiss law:
- 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years - Data necessary to take into account potential claims for damages or similar contractual claims and rights, as well as for the processing of related requests, based on previous business experience and the history of the company;The personal data collected in connection with the processing of contractual claims and rights, as well as for the processing of related inquiries based on previous business experience and common industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years is required, which is applicable in certain cases (Art. 127, 130 OR). At the end of five years, claims for rent, lease and capital interest as well as other periodic services, from the delivery of foodstuffs, for remuneration and for public debts, as well as from the payment of public debts, expire;for landlord's debts, as well as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees (Art. 128 CO).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw your consent at any time.
Right to information: You have the right to request confirmation as to whether the data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the statutory provisions.
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased immediately or, alternatively, in accordance with the legal requirements, to demand the restriction of processing. alternatively, in accordance with the legal requirements, to request that the processing of the data be restricted.
Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to request its transmission to another controller, in accordance with the legal requirements.
Complaint to the supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident;the supervisory authority of your place of work or of the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss FADP:

Right to information: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and related measures and with regard to communication with the contractual partners (or pre-contractual), for example to answer inquiries.

We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper business management as well as in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information and rights (e.g. for the involvement of telecommunication providers, data processors, data processors, data processors, data processors and data processors). For example, the involvement of telecommunications, transportation and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or financial authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, as part of this privacy policy.

We inform the contractual partners of which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks, etc.), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and in principle after the end of the order.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers) postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Service recipients and clients; interested parties; business and contractual partners. Communication partners.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures; business processes and business management procedures; direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors).
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

"Nele.ai": With nele.ai, we offer software that enables users to integrate AI software and create AI content via API access to AI-based services in various application scenarios. User input is not transmitted directly to the AI providers, but processed on our servers. The processing is carried out to fulfill our contractual obligations, which include in particular the storage of user input and the filtering of content. User input is stored on our servers. This includes, in particular, user prompts. Subject to the functions provided by the providers, we only use AI functions with the stipulation to the AI providers that the user input may not be stored by the AI providers or used for learning purposes. Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/legal/privacypolicy/; Data Processing Agreement: Provided by the service provider. Basis for third country transfers: Switzerland - adequacy decision (Germany).

Providers and services used as part of our business activities

We use additional services, platforms, interfaces or plug-ins from third-party providers ("services" for short) as part of our business activities in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); data subject data (e.g. e-mail addresses or telephone numbers). postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
Persons concerned: Service recipients and clients; interested parties; business and contractual partners; users (e.g. website visitors, users of online services). Third parties
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Office and organizational procedures; Business processes and business administration procedures; Artificial intelligence (AI); Provision of our online services and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
Storage and erasure: erasure in accordance with the information in the section "General information on data storage and erasure".
Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Further information on processing operations, procedures and services:

OpenAI API: Interface access (so-called "API") to AI-based services that are designed to understand and generate natural language and related inputs, analyze information and make predictions ("AI", i.e. "AI"). artificial intelligence", is to be understood in the applicable legal sense of the term). The provision of the AI Services includes the processing (including collection, storage, organization and structuring) of personal data as part of a natural language based machine learning process; the performance of activities to verify or maintain the quality of the AI Services;the quality or maintenance of the services; the identification and correction of errors that affect the existing intended functionality and support to ensure the security and integrity of the AI services; Service providers: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openai.com/product; Data protection declaration: https://openai.com/de/policies/eu-privacy-policy; Data processing agreement: https://openai.com/policies/data-processing-addendum; Basis for third country transfers: EU/EEA - standard contractual clauses (https://openai.com/policies/data-processing-addendum), Switzerland - adequacy decision (Ireland). Option to object (opt-out): https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
Microsoft Azure OpenAI Service: Interface access (so-called "API") to AI-based services designed to understand and generate natural language and related inputs, analyze information and make predictions ("AI", i.e. "artificial intelligence", is to be understood in the applicable legal sense of the term). The provision of the AI Services includes the processing (including collection, storage, organization and structuring) of personal data as part of a natural language based machine learning process; the performance of activities to verify or maintain the quality of the AI Services;or maintaining the quality of the services; identifying and resolving errors that affect the existing intended functionality; and assisting in ensuring the security and integrity of the AI services; Service Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://azure.microsoft.com/de-de/products/ai-services/openai-service; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Data processing agreement: https://azure.microsoft.com/de-de/support/legal/. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).
Claude API: Interface access (so-called "API") to AI-based services designed to understand and generate natural language and related inputs, analyze information and make predictions ("AI", i.e. "artificial intelligence", is to be understood in the applicable legal sense of the term). The provision of the AI Services includes the processing (including collection, storage, organization and structuring) of personal data as part of a natural language based machine learning process; the performance of activities to verify or maintain the quality of the AI Services;the quality or maintenance of the services; the identification and correction of errors that affect the existing intended functionality and support to ensure the security and integrity of the AI services; Service providers: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.anthropic.com/; AGB: Anthropic PBC, 548 Market Street, PMB 90375, San Francisco, CA 94104, USA; Privacy Policy: https://www.anthropic.com/legal/privacy; Data processing agreement: https://www.anthropic.com/legal/commercial-terms. Basic third country transfers: EU/EEA - standard contractual clauses (https://www.anthropic.com/legal/commercial-terms), Switzerland - standard contractual clauses (https://www.anthropic.com/legal/commercial-terms).
Google Gemini: AI-powered system designed to provide advanced speech and image processing capabilities. It uses machine learning to understand and generate natural language and analyze images, thus offering versatile application possibilities in various areas; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://cloud.google.com/; Data protection declaration: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/processorterms/?hl=de. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).

Payment methods

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment methods and use other service providers in addition to banks and credit institutions (collectively "payment service providers") for this purpose.

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the payment service provider's terms and conditions and privacy policy.

For payment transactions, the terms and conditions and the data protection notices of the respective payment service providers apply, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and visits to the website); data subject of the contract (e.g. name, address, contact information). usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Contact data (e.g. postal and email addresses or telephone numbers).
Affected persons: Service recipients and clients; business and contractual partners. Interested parties.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; business processes and business procedures. Office and organizational procedures.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal bases: Performance of contracts and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Stripe: Payment services (technical connection of online payment methods); Service provider: Stripe, Inc, 510 Townsend Street, San Francisco, CA 94103, USA; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy. Basic third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).
pathway solutions: Retrieval and processing of orders, customer data and payment data from store systems and other transaction platforms via interfaces. The collected data is then converted into booking information optimized for booking procedures; Service provider: Pathway Solutions GmbH, Alstertwiete 3, 20099 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pathway-solutions.de/; Data protection declaration: https://www.pathway-solutions.de/pages/datenschutzerklaerung; Data processing agreement: Provided by the service provider. Basis for third country transfers: Switzerland - adequacy decision (Germany).

Provision of the online service and web hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication data and process data (e.g. IP addresses, time data). e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and posts as well as the information relating to them, such as information on authorship or time of creation).
Persons concerned: Users (e.g. website visitors, users of online services). Business and contractual partners.
Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); Security measures. Office and organizational procedures.
Storage and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Brevo: Email dispatch; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Data processing agreement: Provided by the service provider; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Website: https://www.brevo.com/. Privacy Policy: https://www.brevo.com/legal/privacypolicy/.
Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally resolved.
Hetzner: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity). e.g. storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/en/legal/data-protection; Order processing contract: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/. Basis for third country transfers: Switzerland - adequacy decision (Germany).
Webflow: Creation, management and hosting of websites, online forms and other web elements; Service provider: Webflow, Inc., 398 11th St., Floor 2, 94103 San Francisco, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://webflow.com; Privacy Policy: https://webflow.com/legal/eu-privacy-policy; Order processing contract: https://webflow.com/legal/dpa. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Data Privacy Framework (DPF).

Use of cookies

The term "cookies" refers to functions that store information on users' end devices and read it from them. Cookies can also be used for various purposes, for example to improve the functionality, security and convenience of online services and to analyze visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user's consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.

Notes on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and processes.

Storage period: A distinction is made between the following types of cookies with regard to the storage period:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their end device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device has been closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to processing in accordance with the legal requirements, including by means of the privacy settings of their browser.

Types of data processed: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Users (e.g. website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

Processing of cookie data on the basis of consent: We use a consent management solution in which the consent of users to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option to manage and withdraw their consent. The declarations of consent are stored in order to avoid a new request and to be able to provide proof of consent in accordance with the legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the terminal device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Cookie Consent Manager CCM19: Consent management: Process for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users' end devices and their processing; Service provider: Papoo Software & Media GmbH, Auguststr. 4, 53229 Bonn, Germany; Website: https://www.ccm19.de/; Data protection declaration: https://www.ccm19.de/datenschutzerklaerung.html; Basis for third country transfers: Switzerland - adequacy decision (Germany). Further information: A pseudonymous user ID with the consent status is stored.

Registration, login and user account

Users can create a user account. As part of the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (user name, password and an email address).

We store the IP address and the time of the respective user action as part of the use of our registration and login functions and the use of the user account. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users may be informed by email about events that are relevant to their user account, such as technical changes.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and posts); Data subject data (e.g. email addresses, telephone numbers, etc.). content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Log data (e.g. log files relating to logins or the retrieval of data or access times).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online offer and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Deletion after termination.
Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures and services:

Registration with a clear name: Because of the nature of our community, we ask users to only use our services using real names. This means that the use of pseudonyms is not permitted; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Users' profiles are not public: Users' profiles are not publicly visible or accessible.
Deletion of data after termination: If users have terminated their user account, their data will be deleted with regard to the user account, subject to legal permission, obligation or consent of the users; Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
No obligation to retain data: It is the responsibility of the users to save their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Contact and inquiry management

When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the information of the enquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions); Data subject data (e.g. e-mail addresses, telephone numbers, etc.). content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Communication partners.
Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
Storage and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure".
Legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

Contact form: When you contact us via our contact form, by email or other communication channels, we process the personal data provided to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter "newsletter") exclusively with the consent of the recipients or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration, these contents are decisive for the user's consent. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the email address in a blocklist for this purpose alone.

The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about nele.ai, AI systems and our services.

Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
Persons concerned: Communication partners.
Purposes of processing: Direct marketing (e.g. by email or post). Reach measurement (e.g. access statistics, recognition of returning visitors).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Option to object (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.

Further information on processing operations, procedures and services:

Measurement of opening and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server or its server, if we use a mailing service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until deletion. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of the opening and click rates and the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user's consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Brevo: Email delivery and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/legal/privacypolicy/; Processing Agreement: Provided by the service provider. Basis for third country transfers: Switzerland - adequacy decision (Germany).

Web analysis, monitoring and optimization

Web analysis (also referred to as "reach measurement") is used to evaluate the visitor flows of our online offer and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used, or invite visitors to reuse them. We are also able to understand which areas require optimization.

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

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored for the purposes of web analysis, A/B testing and optimization, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Users (e.g. website visitors, users of online services).
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offer and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users' devices for a period of two years.
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, which they have accessed again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based items). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for any other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland); Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).
Google Tag Manager: We use Google Tag Manager, a software from Google that allows us to centrally manage so-called website tags via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. Google Tag Manager itself does not create any user profiles, does not store any cookies with user profiles and does not carry out any independent analyses. Its function is limited to simplifying the integration and management of tools and services that we use on our website and making them more efficient. Nevertheless, when using the Google Tag Manager, the IP address of the user is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this privacy policy; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Data protection declaration: https://policies.google.com/privacy; Order processing contract:
https://business.safety.google/adsprocessorterms. Basis for third country transfers: EU/EEA - Data Privacy Framework (DPF), Switzerland - Adequacy Decision (Ireland).

Online marketing

We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising spaces or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the user data relevant for the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

In addition, the IP addresses of users are stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we and the providers of the online marketing processes do not know the actual user identity, but only the information stored in their profiles.

The statements in the profiles are usually stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.

Exceptionally, it is possible to assign clear data to the profiles, primarily if, for example, the users are members of a social network whose online marketing process we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.

In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Information on revocation and objection:

We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are summarized for each area:

a) Europe: https://www.youronlinechoices.eu.

b) Canada: https://www.youradchoices.ca/choices.

c) USA: https://www.aboutads.info/choices.

d) Cross-territory: https://optout.aboutads.info.

Types of data processed: Usage data (e.g. page views and duration of visit, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Inventory data (e.g. full name, residential address, contact information, customer number, etc.).
Affected persons: Users (e.g. website visitors, users of online services). Service recipients and clients.
Purposes of Processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behavior, use of cookies); Custom Audiences; Marketing. Profiles with user-related information (creation of user profiles).
Storage and erasure: Erasure in accordance with the information in the section "General information on data storage and erasure". Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

No use within the nele.ai app: We would like to point out that the online marketing measures are used solely on our websites, but not within the nele.ai app. This means, in particular, that no user prompts or input are processed for marketing purposes.
Leadinfo: Leadinfo analyzes general website usage data to identify trends and patterns in visitor behavior. It provides summarized information about companies, supports the classification of potential prospects, enables notification systems and allows linking with CRM systems. How it works: Leadinfo identifies visits by companies to our website using IP addresses and provides us with publicly available information such as company names or addresses. In addition, Leadinfo uses two first-party cookies to evaluate user behavior on our website and processes domains from form submissions (e.g. "leadinfo.com") to correlate IP addresses with companies and improve services; Service provider: Leadinfo B.V., Rivium Quadrant 141, 2909 LC Capelle aan den IJssel, Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.leadinfo.com; Privacy Policy: https://www.leadinfo.com/de/rechtliches/datenschutz/; Data processing agreement: https://portal.leadinfo.com/settings/legal; Basis for third country transfers: Switzerland - adequacy decision (Netherlands). Option to object (opt-out): https://www.leadinfo.com/de/rechtliches/opt-out/.

Offer of an affiliate program

We offer an affiliate program, i.e. commissions or other benefits (collectively referred to as "commission") for users (referred to as "affiliates") who refer to our offers and services. The reference is made by means of a link assigned to the respective Affiliate or other methods (e.g. discount codes) that allow us to recognize that the use of our services was based on the reference (collectively referred to as "Affiliate Links").

In order to be able to track whether users have used our services based on the affiliate links used by the affiliates, it is necessary for us to know that the users have followed an affiliate link. The assignment of the affiliate links to the respective business transactions or other use of our services serves the sole purpose of commission settlement and is canceled as soon as it is no longer necessary for this purpose.

For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented by certain values that are part of the link or can be stored elsewhere, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Notes on legal bases: The processing of our partners' data is carried out for the provision of our (pre-)contractual services. Users' data is processed on the basis of their consent.

Types of data processed: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); log data (e.g. log files relating to logins). e.g. log files relating to logins or the retrieval of data or access times); inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons concerned: Users (e.g. website visitors, users of online services). Business and contractual partners.
Purposes of Processing: Provision of contractual services and fulfillment of contractual obligations; Affiliate Tracking; Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities). Marketing.
Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

Rewardful: Operation of an affiliate system with commission calculation and management of affiliates, integration of payment processors as well as generation and conversion analysis of referral links; Service provider: Rewardful Inc, 888 - 3RD STREET SW, SUITE 3810, BANKERS HALL WEST, Calgary, Alberta, T2P 5C5, Canada; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.rewardful.com/; Privacy Policy: https://www.rewardful.com/privacy; Data Processing Agreement: Provided by the service provider. Basis for third country transfers: EU/EEA - adequacy decision (Canada), Switzerland - adequacy decision (Canada).

Amendment and updating

We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

Affiliate tracking: As part of affiliate tracking, links that the linking websites use to refer users to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as, e.g. B. advertising material ID, partner ID and categorizations
Inventory data: Inventory data includes essential information that is necessary for the identification and administration of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities or systems by enabling unique assignment and communication.
Content Data: Content Data includes information generated in the course of creating, editing and publishing content of any kind. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication data
Contact data: Contact data is essential information that enables communication with people or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
Artificial intelligence (AI): The purpose of data processing by artificial intelligence (AI) includes the automated analysis and processing of user data in order to recognize patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of data, the training and application of AI models as well as the continuous review and optimization of the results and is carried out exclusively with the consent of the users or on the basis of legal permission.
Meta, communication and process data: Meta, communication and process data are categories that contain information about the way in which data is processed, communicated and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information about the file size, the creation date, the author of a document and the change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat exchanges, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they use to navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. They are particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or an identifier (e.g. an IP address). cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and the use of websites). Depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.), to analyze, evaluate or predict them (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Log data: Log data is information about events or activities that have been logged on a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to generate performance reports.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the visitor flows of an online offer and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can recognize, for example, at what time users visit their websites and what content they are interested in. This enables them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
Tracking: The term "tracking" is used when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
Controller: The "controller" is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
Contract data: Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
Payment Data: Payment Data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information about payment status, chargebacks, authorizations and fees.
Target group formation: Target group formation (custom audiences) is the term used when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.

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