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Privacy Policy

This privacy policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as „data“) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter collectively referred to as „online offer“). With regard to the terms used, such as „processing“ or „processing“, the „Controller“ we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Person responsible

Company: HUMAN IN LIGHT LLC

Owner: Iris Hoyer

Address: 2880 W OAKLAND PARK, BLVD SUITE 225C, OAKLAND PARK 33311, USA

Phone: +49 (0)171 – 4766339

E-Mail: info@iris-hoyer.de

Link to the legal notice: https://iris-hoyer.de/impressum/

Types of data processed:

Inventory data (e.g., names, addresses).

Contact details (e.g., e-mail, telephone numbers).

Content data (e.g., text entries, photographs, videos).

Usage data (e.g., websites visited, interest in content, access times).

Meta/communication data (e.g., device information, IP addresses). Business-related processing:

We also process

Contract data (e.g., subject matter of the contract, term, customer category).

Payment data (e.g., bank details, payment history)

from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Collection of access data and log files:

We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access,

Browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content that you send to us as the site operator, our website uses SSL or TLS encryption. This means that data that you transmit via this website cannot be read by third parties. You can recognize an encrypted connection by the „https:// “ address line of your browser and the lock symbol in the browser line.

Provision of contractual services:

We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.

As part of the use of our online services, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as those of the user 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 in accordance with Art. 6 para. 1 lit. c GDPR.

We process usage data (e.g., the websites visited on our online offering, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile, e.g., to display product information to users based on the services they have used to date.

The deletion of the data takes place after the expiry of statutory warranty and comparable obligations; the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry. Information in any customer account remains until it is deleted.

Categories of data subjects:

Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as „users“).

Purpose of the processing:

– Provision of the online offer, its functions and content.

– Answering contact requests and communicating with users.

– Safety measures.

– Reach measurement/marketing Terms used:

„Personal data“ means any information r e l a t i n g to an identified or identifiable natural person (hereinafter „data s u b j e c t „); 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. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

„Processing“ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

„Pseudonymization“ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

„Profiling“ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

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.

„Processor“ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases:

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

Safety measures:

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, 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, to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties:

If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6 para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we entrust third parties with the processing of data on the basis of a so-called „order processing contract“, this is done on the basis of Art. 28 GDPR.

Transfers to third countries:

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third- party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place

e.g. on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA by the

„Privacy Shield“) or compliance with officially recognized special contractual obligations (so-called „standard contractual clauses“).

Rights of the data subjects:

You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority.

Right of withdrawal:

You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future

Right of objection

You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.

Cookies and right to object to direct advertising

Cookies“ are small files that are stored on users‘ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or „session cookies“ or „transient cookies“, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status can be stored in such a cookie, for example. As

„Permanent“ or „persistent“ cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the user visits the website after several days.

The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. As

„Third-party cookies“ are cookies offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as „first-party cookies“).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in t h e browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data:

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes

purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, storage is carried out in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).

According to legal requirements in Austria, the retention period is 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One- Stop-Shop (MOSS) is used.

Cookies and right to object to direct advertising

Cookies“ are small files that are stored on users‘ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or „session cookies“ or „transient cookies“, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. As

„Permanent“ or „persistent“ cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the user visits the website after several days.

The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. As

„Third-party cookies“ a r e cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as „first-party cookies“).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser.

Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in t h e browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, the retention period is 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, the retention period is 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One- Stop-Shop (MOSS) is used.

Coaching

We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as „clients“) in accordance with Art. 6 para. 1 lit. b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data generally includes inventory and master data of clients (e.g. name, address, etc.), as well as contact data (e.g. e-mail address, telephone, etc.), contract data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g. bank details, payment history, etc.).

As part of our services, we may also process special categories of data in accordance with Art. 9 para. 1 GDPR, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, ethnic origin or religious or ideological beliefs.

For this purpose, we collect, if necessary, in accordance with Art. 6 para. 1 lit. a., Art. 7, Art. 9 para. 2 lit.

a. GDPR and otherwise process the special categories of data for the purposes of preventive healthcare on the basis of Art. 9 para. 2 lit h. GDPR, § 22 para. 1 no. 1 b. BDSG.

If necessary for the fulfillment of the contract or required by law, we disclose or transmit the client’s data in the context of communication with other professionals, third parties involved in the fulfillment of the contract, such as billing offices or comparable service providers, insofar as this serves the provision of our services in accordance with Art. 6 para. 1 lit b. GDPR, is required by law pursuant to Art. 6 para. 1 lit. c. GDPR, serves our interests or those of our clients in efficient and cost-effective healthcare as a legitimate interest pursuant to Art. 6 para. 1 lit f. GDPR or is necessary pursuant to Art. 6 para. 1 lit. d. GDPR to protect the vital interests of clients or another natural person or in the context of consent pursuant to Art. 6 para. 1 lit. a., Art. 7 GDPR.

The data w i l l be deleted when the data is no longer required to fulfill contractual or statutory duties of care and to deal with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise the statutory retention obligations apply.

Contractual services

We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as „contractual partners“) in accordance with Art. 6 para. 1 lit. b. GDPR. GDPR in order t o provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

In principle, we do not process special categories of personal data unless these are part of commissioned or contractual processing.

We process data that is required to justify and fulfill the contractual services and point out the necessity of its disclosure, unless this is evident to the contractual partners.

Disclosure to external persons or companies only takes place if it is necessary within the framework of a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements.

As part of the use of our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of 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 in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR.

The data i s deleted when it is no longer required for the fulfillment of contractual or statutory duties of care and for dealing with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise the statutory retention obligations apply.

Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as

e.g. archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

We also store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We generally store this data, most of which is company- related, permanently.

Business analyses and market research

In order to operate our business economically, identify market trends and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses help us to increase user-friendliness, optimize our offer and improve business efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they will be deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously where possible.

Participation in affiliate partner programs

Within our online offer, we use industry-standard tracking measures on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) in accordance with Art. 6 para. 1 lit. f GDPR, insofar as these are necessary for the operation of the affiliate system. Below we explain the technical background to users.

The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, e.g. if links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take advantage of the offers.

In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available from us subsequently take advantage of the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be set as part of the link or otherwise, e.g. in a cookie. The values include, in particular, the source website (referrer), 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 advertising material ID, partner ID and categorizations.

The online identifiers we use for users are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or e-mail addresses. They only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offer took up the offer,

i.e. e.g. has concluded a contract with the provider. However, the online identifier is personal to the extent that the partner company and we have the online identifier together with other user data. Only in this way can the partner company inform us whether the user has taken up the offer and we can, for example, pay out the bonus.

Partner programs Amazon

We participate in the Amazon EU partner program. In our online offer, Amazon integrates advertisements and links to the Amazon.de site, from which we can earn some money by reimbursing advertising costs. Amazon u s e s cookies to track the origin of orders. This allows Amazon to recognize that you have clicked on an affiliate link on our website.

You can find more information on the use of data by Amazon in Amazon’s privacy policy: https://www.amazon.de/gp/help/customer/ display.html?nodeId=201909010

The storage of „Amazon cookies“ takes place on the basis of Art. 6 lit. f GDPR. As the website operator, we have a legitimate interest in this, as the amount of my affiliate remuneration can only b e determined through the cookies.

Digistore24

On the basis of our legitimate interests (i.e. interest in the economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we are a participant in the affiliate program of Digistore24 GmbH. GDPR), we are participants in the affiliate program of Digistore24 GmbH, St.-Godehard- Straße 32, 31139 Hildesheim, Germany, which was designed to provide a medium for websites by means of which advertising costs can be earned through the placement of advertisements and links to Digistore24 (so-called affiliate system). Digistore24 u s e s cookies in order to be able to trace the origin of the conclusion of the contract. Among other things, Digistore24 can recognize that you have clicked on the partner link on this website and subsequently concluded a contract with or via Digistore24.

Further information on the use of data by Digistore24 and objection options can be found in the company’s privacy policy: https://www.digistore24.com/page/privacyl.

Registration function

Users can create a user account. As part of the registration process, the required mandatory information is communicated to the users and processed on the basis of Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users can access information relevant to their user account, such as

e.g. technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to a statutory retention obligation. It is the responsibility of users to back up 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.

As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as those of the user in protection against misuse and other unauthorized use. This data i s not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR.

GDPR. The IP addresses are anonymized or deleted after 7 days at the latest. Soundcloud

Our podcasts are stored on the platform „Soundcloud“, offered by SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany and are played back from this platform.

For this purpose, we integrate so-called Soundcloud widgets into our website. These are playback software with which users can play the podcasts. Soundcloud can measure which podcasts are listened to and to what extent and process this information pseudonymously for statistical and business purposes. For this purpose, cookies may be stored in users‘ browsers and processed for the purpose of creating user profiles, e .g. f o r t h e purpose of displaying advertisements that correspond to the potential interests of users. In the case of users who are registered with Soundcloud, Soundcloud can assign the listening information to their profiles.

The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimization of our audio offer in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR.

Further information and objection options can be found in Soundcloud’s privacy policy: https://soundcloud.com/pages/privacy.

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details will be used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. The user’s details may be stored in a customer relationship management system („CRM system“) or comparable inquiry organization.

We delete the requests if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter „newsletter“) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no- one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to enter your e- mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.

The newsletter and the performance measurement associated with it a r e sent on the basis of the consent of the recipients in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 para. 1 lt.

f. GDPR i n conjunction with. § 7 para. 3 U W G .

The registration process is logged on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.

Cancellation/revocation – You can cancel the receipt of our newsletter at any time,

i.e . revoke your consent. You will find a link to unsubscribe from t h e n e w s l e t t e r a t the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data i s limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

Newsletter – Brevo

The newsletter is sent by the mailing service provider Sendinblue GmbH, Köpenicker Straße 126 10179 Berlin, Germany. You can view the privacy policy of the mailing service provider here: https://www.brevo.com/legal/privacypolicy/. The shipping service provider is used on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR and an order processing contract pursuant to Art. 28 para. 3 sentence 1 GDPR.

The mailing service provider may use the recipients‘ data in pseudonymous form,

i.e. without assigning it to a user, to optimize or improve its own services, e.g. to technically optimize the mailing and presentation of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

Hosting and e-mail delivery

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e- mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.

We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract). Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f.

GDPR), we use Google Analytics, a web analysis service provided by Google LLC („Google“). GDPR) Google Analytics, a web analysis service of Google LLC („Google“). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https:// www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http:// tools.google.com/dlpage/gaoptout?hl=en.

Further information on the use of data by Google, setting and objection options, can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https:// adssettings.google.com/authenticated).

Users‘ personal data is deleted or anonymized after 14 months. Google AdWords and conversion measurement

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit.

f. GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA („Google“). GDPR) the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, („Google“).

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https:// www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing process Google „AdWords“ to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users w h o are likely to be interested in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only w i t h ads that potentially match their interests. If, for example, a user is shown ads for products that they have shown an interest in on other online offers, this is referred to as „remarketing“. For these purposes, when our and other websites on which the Google advertising network is active are accessed, a code from G o o g l e is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as „web beacons“) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, time of visit and other information about the use of the online offer.

We also receive an individual „conversion cookie“. The information obtained with the help of the cookie is used by Google to create conversion statistics for us.

However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information with which users can be personally identified.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the name or e-mail address of the user.

Google does not use the user’s email address, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about the user is transmitted to Google and stored on Google’s servers in the USA.

Further information on the use of data by Google, setting and objection options, can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https:// adssettings.google.com/authenticated).

Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them about our services.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users‘ rights. With regard to US providers that are certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of users‘ personal data is based on our legitimate interests in effective user information and communication with users in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR. If users are asked by the respective providers to consent to data processing (i.e. to give their consent, e.g. by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.

For a detailed description of the respective processing and the opt-out options, we refer to the following linked information from the providers.

In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users‘ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy Policy: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads and http:// www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/ participant?id=a2zt0000000GnywAAC&status=Active.

Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https:// www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy/ Opt-Out: http://instagram.com/about/legal/privacy/.

Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Policy: https://twitter.com/de/privacy, Opt-Out: https:// twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/ participant?id=a2zt0000000TORzAAO&status=Active.

Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Policy/ Opt-Out: https://about.pinterest.com/de/privacy-policy.

LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Policy https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant? id=a2zt0000000L0UZAA0&status=Active.

Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Policy/ Opt-Out: https://privacy.xing.com/de/ datenschutzerklaerung.

Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom)

Privacy policy/ opt-out: https://wakelet.com/privacy.html.

Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Policy/ Opt-Out: https://soundcloud.com/pages/ privacy.

Integration of third-party services and content

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f.

GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers to integrate their content and services, s u c h a s videos or fonts (hereinafter uniformly referred to as „content“).

This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content.

Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes.

Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.

Vimeo

We can integrate the videos of the platform „Vimeo“ of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy policy: https://vimeo.com/privacy. We would like to point out that Vimeo may use Google Analytics and refer you to the privacy policy (https://www.google.com/policies/privacy) and opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout? hl=en) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/.).

Youtube

We integrate the videos of the platform „YouTube“ of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https:// adssettings.google.com/authenticated.

Google Fonts

We integrate the fonts („Google Fonts“) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https:// adssettings.google.com/authenticated.

Google ReCaptcha

We integrate the function for recognizing bots, e.g. for entries in online forms („ReCaptcha“) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https:// www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/ authenticated.

Google Maps

We integrate the maps of the „Google Maps“ service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data may be processed in the USA. Privacy policy: https://www.google.com/ policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

Typekit fonts from Adobe

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use external „Typekit“ fonts from the provider Adobe Systems Software Ireland Limited. GDPR), we use external „Typekit“ fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant? id=a2zt0000000TNo9AAG&status=Active).

Use of Facebook social plugins

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f.

GDPR), we use social plugins („plugins“) of the social network facebook.com, which is operated by Facebook Ireland Ltd. GDPR) social plugins („plugins“) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland („Facebook“).

This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https:// www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user accesses a function of this online offering that contains such a plugin, their device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering. Thereby

user profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out their IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options for protecting the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/ about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about them via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/ settings?tab=ads or via the US site http://www.aboutads.info/ choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

Xing

Functions and content of the Xing service, offered by XING AG, Dammtorstraße 29- 32, 20354 Hamburg, Germany, may be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Xing. If the users are members of the Xing platform, Xing can assign the access to the above-mentioned content and functions to the users‘ profiles there. Xing’s privacy policy: https:// privacy.xing.com/de/datenschutzerklaerung.

Contact the data protection officer:

If you have any questions about data protection, please send us a message to e-mail: info@iris-hoyer.de with the subject „Data protection“.