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Data Protection

We are pleased about your interest in our company. Data protection is of high priority for the management of TWNTY Digital GmbH. The usage of the Internet pages of the TWNTY Digital GmbH is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, the processing of personal data could become necessary. If the processing of personal data is essential, and there is no legal basis for such processing, we will normally get the permission of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, shall always be in line with the country-specific data protection regulations applicable to the TWNTY Digital GmbH. Using this data protection statement, our company aims to provide an overview of the personal
data we collect, use, and process for the benefit of the public.

Furthermore, data subjects are informed of their rights using this data protection statement. As the controller, the TWNTY Digital GmbH has implemented numerous technical and organizational measures because privacy is of utmost importance processed through this website. Nevertheless, Internet-based data transmissions can always be vulnerable to security risks, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example, by telephone.

1. Definitions

The data protection declaration of TWNTY Digital GmbH is based on the terms used by the European Directive and Ordinance when issuing the Data Protection Regulation (DS-GVO). Our privacy policy should be easy to read and comprehend for both the general public and our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this privacy policy:

a) Personal data

Personal data is any information relating to an identified or identifiable natural person (hence “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, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Betroffene Person

The data subject is any identified or identifiable natural person whose personal data are processed by the controller.

c) Processing

Any action or set of actions performed on personal data, whether or not automatically, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction, is referred to as processing.

d) Restriction of processing

Restriction of processing is the marking of stored personal data to limit their future processing.

e) Profiling

Profiling is any automated processing of personal data that evaluates or predicts characteristics of a natural person’s work performance, economic condition, health, personal preferences, interests, dependability, behavior, location, or change of location.

f) Pseudonymization

Pseudonymization is any processing of personal data where the personal data can no longer be associated with any specific data subject without additional information. This additional information must be kept separate and subject to appropriate technical and organizational measures to ensure that the personal data cannot be attributed to an identified or identifiable natural person.

g) The person in charge of or accountable for the processing

The controller is the natural or legal person, public authority, agency, or other organization that decides the goals and methods of processing personal data alone or collectively with others. The controller or theparticular criteria for its identification may be provided for by Union or Member State legislation when the aims and methods of such processing are defined by Union or Member State law.

h) Processor

A processor is a natural or legal person, authority, institution, or other body that processes personal data on behalf of the person responsible.

i) Recipient

A recipient is a natural or legal person, public authority, agency, or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law shall not be considered recipients.

j) Third party

Third-party means a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

k) Consent

The term “consent” refers to any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

2. Name and address of the controller

The responsible party within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:

TWNTY Digital GmbH, Pfaffendorfer Str. 26
04105 Leipzig/Germany

Phone: +49 (0)341 221 796 00

E-mail: info@trafficgeeks.io

Managing Director: Kay Theuer
Local court Leipzig // Registration number: HRB 31482
Sales tax identification number: DE29766576016
Responsible for the content: Kay Theuer

3. Cookies

4. Collection of general data and information

The website of the TWNTY Digital GmbH collects a series of general data and information with each call-up of the website by a data subject or automated system. This total data and information are stored in the log files of the server.

The following can be recorded: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (the so-called referrer), (4) the sub- websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

TWNTY Digital GmbH does not draw any conclusions about the data subject from the use of these general facts and information. Actually, this information is required

(1) to deliver the contents of our website correctly

(2) to optimize the contents of our website and the advertising for these

(3) to ensure the long-term functionality of our information technology systems and the technology of our website

(4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

As a result, TWNTY Digital GmbH analyzes anonymously acquired data and information on the one hand, while increasing our enterprise’s data protection and  data security on the other, so that we can eventually provide an ideal degree of protection for the personal data we handle.

5. Registration on our website

The data subject has the opportunity to register on the website of the controller by providing personal data. The input mask used for registration determines which personal data is transmitted to the controller.

The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, for example, a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.

As part of the registration process on the controller’s website, an individual’s IP address, the date and time of the registration, also the date and time of the registration are all saved. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented and, if necessary, this data makes it possible to clarify committed crimes. In this respect, the storage of this data is vital for the protection of the data controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.

The registration of the data subject by voluntarily providing personal data serves the purpose of the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users.

Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data stock of the  controller. The controller shall provide any data subject at any moment upon request with information about what personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any statutory retention obligations. The entire staff of the controller shall be available to the data subject as contact persons in this context.

6. Subscription to our newsletter

Users may subscribe to the TWNTY Digital GmbH’s newsletter on the company’s website. The input mask used for this purpose specifies the personal data communicated to the controller when the newsletter is ordered.

The TWNTY Digital GmbH informs its customers and business partners regularly through a newsletter aboutenterprise  offers. The newsletter of our enterprise can only be received by the data subject, if

(1) the data subject has a valid e-mail address

(2) the data subject registers for the newsletter mailing.

For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by a data subject for the first time for newsletter dispatch using the double-opt-in procedure. This confirmation e-mail serves to verify whether the owner of the e- mail address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the Internet service provider (ISP), also the date and time of registration. The collection of this data is necessary to trace the (possible) misuse of the e-mail address of a data subject at a later point in time and therefore serves the legal protection of the controller.

The personal data collected in registration for the newsletter are used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service  or a related registration, as could be the case in the event of changes to the newsletter offer or changes in technical circumstances. No personal information obtained via the newsletter service will be shared with third parties.

The data subject has the right to withdraw his subscription to our newsletter at any time. The data subject’s permission to the storing of personal data for the purpose of newsletter delivery may be canceled at any moment. Each newsletter  has a link that one may use to unsubscribe permission. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on the controller’s website at any time, or to notify the controller of this in another way.

7. Newsletter tracking

The newsletters of TWNTY Digital GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such e-mails that are sent in HTML format to enable log file recording and log file analysis. It allows a  statistical evaluation of the success or failure of online marketing campaigns.

TWNTY Digital GmbH can identify if and when an e-mail was opened by a data subject. This concern which links in the e-mail were clicked by the data subject, based on the embedded tracking pixel. Such personal data collected via the tracking pixel contained in the newsletters are stored and analyzed by the controller tooptimize the newsletter dispatch and to better tailor the content of future newsletters to the interests of the data subject.

This personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via  the double-opt-in procedure. After a revocation, this personal data will be deleted by the controller. The TWNTY Digital GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website

Based on statutory provisions, the website of the TWNTY Digital GmbH contains data that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).

The personal data transmitted by the data subject will be stored automatically if a data subject contacts the controller by e-mail or by using a contact form. Such personal data transmitted voluntarily by a data subject to the controller will be stored for processing or contacting the data subject. No disclosure of this personal data to third parties will take place.

9. Subscription to comments in the blog on the website

Generally, third parties may subscribe to the comments posted on TWNTY Digital GmbH’s blog. In particular, a commentator can subscribe to the comments following one’s comment on a specific blog post. If a data subject chooses to subscribe to comments, the controller will send an automated confirmation e-mail. The purpose is to confirm that the owner of the supplied e-mail address has properly chosen this option via a double opt-in method. The option to subscribe to comments can be terminated at any time.

10. Routine deletion and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or another legislator in laws or regulations to which the controller is subject. If the storage purpose ceases to apply or if a storage period prescribed by the European Directive and Regulation Maker or another competent legislator expires, the personal data will be routinely blocked or deleted under the statutory provisions.

11. Rights of the data subject

a) Right to confirmation

Every data subject shall have the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller to confirm whether or not personal data concerning one are being processed. If a data subject wishes to exercise this right, one may, at any time, contact any employee of the controller.

b) Right to information

Any person concerned by the processing of personal data has the right granted by the European Directive and Regulation to obtain at any time from the controller, free of charge, information about the personal data stored about him/her and a copy of that information. In addition, the European Directive and Regulation legislator has granted the data subject access to the following information: the purposes of processing the categories of personal data processed the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations if possible the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration the existence of a right to rectification or erasure of the personal data concerning them or to restriction of processing by the controller or a right to object to such processing the existence of a right of appeal to a supervisory authority if the personal data are not collected from the data subject: Any available automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject Furthermore, the data subject shall have a right of access to whetherpersonal data have been transferred to a third country or to an international organization. If this is the case, the data subject shall also have the right to obtain information about the origin of the data, the existence of appropriate safeguards connected to the transfer. If a data subject wishes to exercise this right of access, he may, at any time, contact any employee of the controller.

c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to request the immediate rectification of inaccurate personal data concerning him/her. Furthermore, the data subject has the right to request the completion of incomplete personal data – also through a supplementary declaration – taking into account the purposes of the processing. If a data subject wishes to exercise this right to rectify, he/she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller the erasure without delay of personal data concerning a person, where one of the following reasons applies and insofar as the processing is no longer necessary. So, the personal data were collected or otherwise processed for purposes, wherefore they are no longer essential. The data subject revokes the person’s consent on which the processing was based according to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO, and there is no other legal basis for the processing. The data subject objects to the processing according to Article 21(1) DS-GVO, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing under Article 21(2) DS-GVO. The personal data has been processed unlawfully. The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject. The personal data have been collected concerning information society services offered according to Article 8(1) DS-GVO. If one of the reasons mentioned above applies, and a data subject wishes to arrange for the erasure of personal data stored by the TWNTY Digital GmbH, he may, at any time, contact any employee of the controller. The employee of the TWNTY Digital GmbH will arrange for the erasure request to be complied with immediately. If the personal data was made public by the TWNTY Digital GmbH and our company is responsible for it according to Art. 17 Para. 1 DS-GVO TWNTY Digital GmbH shall implement reasonable measures. It includes technical measures to compensate other data controllers for processing the personal data published, taking into account the available technology and the cost of implementation, to inform the data subject that he has requested from those other data controllers to erase all links to the personal data, or copies, or replications of the personal data unless the processing is necessary. The employee of the TWNTY Digital GmbH will arrange the necessary in individual cases.e) Right to restriction of processing Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller the restriction of processing if the accuracy of the personal data is contested by the data subject for a period, enabling the controller to verify the accuracy of the personal data. The processing is unlawful if the data subject objects to the erasure of the personal data and requests instead of the restriction of the use of the personal data. The controller no longer needs the personal data for the processing, but the data subject wants it for the assertion, exercise, or defense of legal claims. The data subject has objected to the processing according to Article 21 (1) of the GDPR, and it is not yet clear whether the legitimate grounds of the controller override those of the data subject. If one of the conditions mentioned above is met, and a data subject wishes to request the restriction of personal data stored by the TWNTY Digital GmbH, he may, at any time, contact any employee of the controller. The employee of the TWNTY Digital GmbH will arrange the restriction of the processing.

f) Right to data portability

Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to receive the personal data concerning himself, which have been provided by the data subject to a controller, in a structured, commonly used, and machine-readable format. One also has the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent according to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract according to Article 6(1)(b) of the GDPR. So, the processing is carried out by automated means unless the processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller. Furthermore, when exercising the right to data portability under Article 20(1) of the GDPR, the data subject has the right to request that personal data be transferred directly from one controller to another controller where this is technically feasible and does not endanger the rights and freedoms of others. The data subject may contact any TWNTY Digital GmbH employee at any time to assert their right to data portability.

g) Right of objection

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to object at any time, on grounds relating to his particular situation, to the processing of personal data concerning him carried out based on Article 6(1)(e) or (f) of the GDPR. It also applies to profiling based on these provisions. The TWNTY Digital GmbH shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the assertion, exercise, or defense of legal claims. If the TWNTY Digital GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data processed for such marketing. It also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to the TWNTY Digital GmbH to the processing for direct marketing purposes, the TWNTY Digital GmbH will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his particular situation, to object to the processing of personal data concerning him, which is carried out by the TWNTY Digital GmbH for scientific or historical research purposes, or statistical purposes, according to Article 89(1) of the Data Protection Regulation (DS-GVO), unless such processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may directly contact any employee of the TWNTY Digital GmbH or another employee. The data subject is also free to exercise his right to object through automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

h) Automated decisions in individual cases including profiling

Any data subject concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him, or similarly significantly affects him, unless the decision

(1) is necessary for entering into, or the performance of, a contract between the data subject and the controller

(2) is permitted by Union or Member State law to which the controller is subject and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests

(3) is made with the data subject’s explicit consent.

The TWNTY Digital GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests if the decision

(1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller

(2) it is made with the data subject’s explicit consent.

It includes at least the right to obtain the data subject’s involvement on the part of the controller, to express his point of view, and also to contest the decision. If the data subject wishes to exercise the rights concerning automated decisions, he may, at any time, contact any employee of the controller.

i) Right to revoke consent under data protection law

Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing  of personal data at any time. If the data subject wishes to exercise the right to remove the agreement, he may, at any time, contact any employee of the controller.

12. Data protection during applications and the application process

The controller collects and processes the personal data of applicants to handle the application procedure. The processing may also take place electronically. It is the case, in particular, when an applicant submits relevant application documents to the controller by electronic means, for example, by e-mail or via a web form located on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored to process the employment relationship in compliance with the statutory provisions. If the controller does not  conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Another legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

13. Privacy policy on the use and application of Facebook

The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that generally allows users to communicate and interact with one another in a virtual space. A social network can serve as a platform for sharing opinions and experiences or enable the Internet community to provide personal or company-related information. Facebook allows users of the social network to create private profiles, upload photos, and network via friend requests, among other things.

The operating company of Facebook is Facebook, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. The controller of personal data, if a data subject lives outside the USA or Canada, is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the data controller is called up, and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the informationtechnology system of the data subject is automatically caused by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. At https://developers.facebook.com/docs/plugins/?locale=de_DE , you’ll find a comprehensive list of all Facebook plug-ins. Within the scope of this technical procedure, Facebook receives knowledge of which specific sub-
page of our website is visited by the data subject.

If the data subject is also signed in to Facebook, Facebook will identify which precise sub-page of our website the data subject is accessing each time the data subject accesses our website and for the length of the data subject’s stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject activates one of the Facebook buttons integrated on our website, for example, the “Like” button, or if he comments, Facebook assigns this information to his personal Facebook user account and stores this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is simultaneously logged into Facebook when calling up our website; this takes place regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook, he can prevent the transmission by logging out of his Facebook account before accessing our website.

The data policy published by Facebook, which can be accessed at https://de-de.facebook.com/about/privacy/ , provides information about the collection, processing, and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to press data transmission to Facebook.

14. Privacy policy on the use and application of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with an anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation, and analysis of data about the behavior of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called referrers), which subpages of the website were accessed, or how often and for how long a subpage was viewed. A web analysis is mainly used for the optimization of a website and the cost-benefit analysis of internet advertising. The operating company of the Google Analytics component is Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. If a data subject accesses our Internet sites from a Member State of the European Union or another State party to the Agreement on the European Economic Area, Google uses this addition to shorten and anonymize the IP address of the data subject’s Internet connection.

The purpose of the Google Analytics component is to analyze the flow of visitors  to our website. Among other things, Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us. Thus it shows the activities on our website and provides other services related to the use of our website.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are that we mentioned above? By setting the cookie, Google is enabled to analyze the use of our website. The internet browser on the data subject’s information technology system is automatically caused by the respective Google Analytics component to transmit data to Google for online analysis with each call to one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently enable commission calculations.

Utilizing the cookie, personal information, for example, the access time, the location from which an access originated, and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. Google stores this personal information in the United States of America. Google may disclose this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time using an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the  Internet browser used would also prevent Google from setting a cookie on theinformation technology system of the data subject. Furthermore, a Google Analytics cookie may be removed at any moment using the Internet browser or other software tools.

Furthermore, the data subject can object to the collection of data generated by Google Analytics and related to the use of this website and the processing of this data by Google and prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout . This browser add-on tells Google Analytics via JavaScript that no data and information about visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted, or reinstalled at a later point in time, the data subject must reinstall the browser add-on to deactivate Google Analytics. There is the option of reinstalling or reactivating the browser add-on if it has been removed or deactivated by the data subject or another person within his sphere of control.

https://www.google.de/intl/de/policies/privacy/ provides a more detailed explanation of Google Analytics and http://www.google.com/analytics/terms/de.html .

Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/ .

15. The privacy policy on the use and application of Google Analytics

The controller has integrated Google AdWords on this website. Google Adwords is an Internet advertising service that allows advertisers to place ads in Google’s search engine results and the Google advertising network. Google AdWords allows an advertiser to specify particular keywords in advance and using this, an ad is displayed in Google’s search engine results exclusively when the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, the ads are distributed on topic-relevant websites using an automatic algorithm and in compliance with the previously defined keywords.

The operating company of Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to advertise our website by displaying interesting relevant advertising on the websites of third-party companies and in the search engine results of the Google search engine and to display third-party advertising on our website.

When a data subject accesses our website via a Google advertisement, a so-called conversion cookie that Google restores on the data subject’s information technology system. What cookies have we explained above? A conversion cookie loses its validity after thirty days and is not used to identify the data subject. The purpose of the conversion cookie is to track whether particular subpages, for example, the shopping cart from an online store system, have been called upon by our website, provided the cookie has not yet expired. Through the conversion cookie, we and also Google can track whether a data subject who has accessed our website via an AdWords ad has generated a sale, i.e., have completed or canceled a purchase of goods.

Google uses the data and information collected through the use of the conversion cookie to create visitor statistics for our website. We use these visit statistics to determine the total number of users who were referred to us via AdWords ads. Neither our company nor other advertisers of Google AdWords receive information from Google through which the data subject could be identified.

Through the conversion cookie, personal information, for example, the internet pages visited by the data subject, is stored. Each time the data subject visits our website, personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by using an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the data subject. In addition, a cookie, which sets Google AdWords can get deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to the interest-based advertising by Google. In this case, the data subject must call up the link www.google.de/settings/ads from any internet browsers he uses and make the desired settings there.

16. Privacy policy for the use of Google Web Fonts

On our website, we use so-called web fonts from Google so that we can display a uniform font for you. These fonts are automatically stored in your browser cache when you call up one of our pages to enable the desired display. If your browser does not support the web fonts used, a default font of your computer may be used.

Here, the users’ interests remain unaffected., which outweighs this technical necessity(Art. 6 I S. 1 f DSGVO). You can view Google’s privacy policy here: https://www.google.com/policies/privacy/ .

You can find more information on Google Web Fonts at https://developers.google.com/fonts/faq .

Also, you can see the information and the applicable data protection provisions of Google at https://www.google.de/intl/de/policies/privacy/ .

17. Privacy policy for the use of Font Awesome

Icons from the company Font Awesome are used on our website to be able to display a uniform image of all icons used, regardless of the resolution of this website and the end devices used. These icons are automatically stored in your browser cache when you call up one of our pages to enable the desired display. Here, no interests of the users are affected, which outweighs this technical necessity (Art. 6 I S. 1 f DSGVO). You can view the privacy policy of Font Awesome here: https://fontawesome.com/privacy .

18. Privacy policy on the use and application of Instagram

The controller has integrated components of the service Instagram on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and redistribute such data on other social networks.

The operating company of the Instagram services is Instagram LLC, 1 Hacker Way, Building 14, First Floor, Menlo Park, CA, USA.

With each call of one of the individual pages of this website, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, the internet browser on the informationtechnology system of the data subject is automatically caused by the respective Instagram component. It downloads a representation of the corresponding part from Instagram. Within the scope of this technical procedure, Instagram receives knowledge about which specific subpage of our website the data subject visited.

If the data subject logs in to Instagram at the same time, Instagram recognizes which specific subpage the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Instagram component and assigned by Instagram to the corresponding Instagram account of the data subject. If the data subject activates one of the Instagram buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is simultaneously logged into Instagram when calling up our website; this takes place regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, he can prevent the transmission by logging out of his Instagram account before accessing our website.

You can find further information and the applicable data protection provisions of Instagram at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/ .

19. Privacy policy on the use and application of Twitter

The controller has integrated components of Twitter into this website. Twitter is a multilingual, publicly-accessible microblogging service on which users can publish and distribute so-called tweets, or short messages limited to 140 characters. Anyone can access these short messages, including people who are not registered with Twitter. However, the so-called followers of the respective user do display the tweets. Followers are other Twitter users who follow the tweets of another user. Furthermore, Twitter makes it possible to address a broad audience via hashtags, links, or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

The Twitter component (Twitter button) on the controller’s website immediately triggers the internet browser on the data subject’s information technology system with each page request. It downloads a representation of the corresponding Twitter component from Twitter. You can find detailed information on the Twitter buttons at https://about.twitter.com/de/resources/buttons .

Within the scope of this technical procedure, Twitter receives knowledge of which specific sub-page of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to disseminate the content of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject logs into Twitter simultaneously, Twitter recognizes which specific subpage of our website the data subject is visiting with each call to our website by the data subject and for the entire duration of the respective stay on our website. This information is collected by the Twitter component and assigned by Twitter to the corresponding Twitter account of the data subject. If the data subject activates one of the Twitter buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Twitter user account of the data subject and stored and processed by Twitter. If the data subject is simultaneously logged in to Twitter, it will receive information via the Twitter component that the data subject has visited our website. Of course, if the data subject is simultaneously logged in to Twitter when calling up our website. It takes place regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not want this information to be transmitted to Twitter, he can prevent the transmission by logging out of his Twitter account before accessing our website.

The applicable data protection provisions of Twitter are available at https://twitter.com/privacy?lang=de .

20. Privacy policy on the use and application of Xing

The controller has integrated components of Xing on this website. Xing is an Internet-based social network that allows users to connect with existing business contacts and make new business contacts. Individual users can create a personal profile for themselves on Xing. Companies can, for example, create company profiles or publish job offers on Xing.

The operating company of Xing is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.

Each time one of the individual pages of this website operated by the controller is called up, and on which a Xing component (Xing plug-in) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Xing component. Thus it downloads a representation of the corresponding Xing component from Xing. You can find detailed information on the Xing plug-ins at https://dev.xing.com/plugins . Within the scope of this technical procedure, Xing receives information about which specific subpage of our website is visited by the data subject.

Xing identifies which specific subpage of our website the data subject is viewing each time the data subject calls up our website and for the length of the relevant stay on our website if the data subject is signed in to Xing at the same time. This information is collected by the Xing component and assigned by Xing to the respective Xing account of the data subject. If the data subject uses one of the Xing buttons placed on our website, such as the (Share button), Xing assigns this information to the data subject’s personal Xing user account and records it.

Xing always receives information via the Xing component that the data subject has visited our website if the data subject is simultaneously logged in to Xing when calling up our website; this takes place regardless of whether the data subject clicks on the Xing component or not. If the data subject does not want this information to be transmitted to Xing, he can prevent the transmission by logging out of his Xing account before accessing our website.

The data protection provisions were published by Xing, which you can access at https://www.xing.com/privacy . It provides information about the collection, processing, and use of personal data by Xing. Furthermore, Xing has published data protection information for the XING Share button at https://www.xing.com/app/share?op=data protection .

21. Payment method: Privacy policy for PayPal as payment method

The controller has integrated components of PayPal on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. In addition, PayPal offers the option of processing virtual payments via credit cards if a user does not maintain a PayPal account. A PayPal account is managed via an email address. That’s why there is no classic account number. PayPal makes it possible to initiate online payments to third parties or to receive payments as well. PayPal also assumes trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

If the data subject selects “PayPal” as a payment option during the ordering process in our online store, data of the data subject will be automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data required for payment processing.

The personal data transmitted to PayPal are usually first name, last name, address, email address, IP address, phone number, cell phone number, or other data essential for payment processing. Personal data related to the respective order are also necessary for the processing of the purchase contract.

The purpose of transmitting the data is payment processing and fraud prevention. The controller will transmit personal data to PayPal particularly if there is a legitimate interest for the transmission. The personal data exchanged between PayPal and the controller may be transferred by PayPal to credit reporting agencies. The purpose of this transmission is to check identity and creditworthiness.

PayPal may disclose the personal data to affiliated companies and service providers or subcontractors, insofar as this is necessary for the fulfillment of contractual obligations or the data is to be processed on behalf.

The data subject can revoke the consent to the handling of personal data at any time vis-à-vis PayPal. A revocation does not affect personal data that must necessarily be processed, used, or transmitted for (contractual) payment processing.

You can see the applicable data protection provisions of PayPal at https://www.paypal.com/de/webapps/mpp/ua/privacy-full .

22. Legal basis of processing

Article 6 I lit. a DS-GVO serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Article 6 I lit. b DS-GVO. The same applies to such processing operations, which are necessary forthe accomplishment of pre-contractual measures, for example, in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data might become necessary to protect the vital interests of the data subject or another natural person. It would be the case, for example, if a visitor were to be injured on our premises and, as a result, his name, age, health insurance data, or other vital information had to pass on to a doctor, hospital, or another third party. Then the processing would be based on Art. 6 I lit. d DS-GVO. Finally, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations that are not covered by any of the aforementioned  legal bases, are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject are not overridden. We permit such processing operations in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47 sentence 2 DS-GVO).

23. Legitimate interests in the processing pursued by the controller or a third party

Our legitimate interest, if the processing of personal data is based on Article 6 I lit. f DS-GVO is the execution of our business operations for the benefit of all of our workers and shareholders.

24. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the period has expired, the corresponding data will be routinely deleted if they are no longer required for the contract’s fulfillment or initiation.

25. Legal or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non- provision

We want to inform you that the provision of personal data is partly required by law (for example, tax regulations) or may also result from contractual rules (for example, information on the contractual partner). Sometimes, to conclude a contract, it may be necessary for a data subject to provide us with personal data that we must proceed with. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.

26. Existence of automated decision making

As a responsible company, we do not use automated decision-making or profiling.

27. PRIMELEADS

We use Primeleads, a web analytics service provided by Spyla UG, Ackerstrasse 23-26, 10115 Berlin, Germany, as part of our legitimate interests in the analysis, optimization, and economic operation of our online offering under Article 6(1)(a) DSGVO. Primeleads uses a tracking code on our website, through an analysis of your use of our website is enabled. The information generated by Prime leads is transferred to a server owned by Spyla UG in Germany and stored there. Primeleads uses this information on our behalf to compile and evaluate visitor behavior using probability calculation for a company profile and to provide us with further analysis and optimization services related to website and Internet use. No personal data is collected through your visit with Primeleads, so a direct identification of a specific person is not possible through this.

Data will be deleted as soon as the underlying purpose ceases to apply and there are no legal retention obligations to the contrary or other justifications under data protection law have arisen.

Primeleads won’t be any further use of personal data. You can revoke your consent of the further collection of data generated by Primeleads and related to your use of the website and the processing of this data by Spyla UG based on your consent.

28. Pipedrive

The websites of TWNTY Digital GmbH use Pipedrive to improve customer relationship management activities.

The responsible company is:

Pipedrive OÜ, Paldiski MNT 80, Tallinn 10617, Estonia.

Any information, including personal data, collected by any other service listed in this Privacy Policy may be sent to and stored on Pipedrive’s servers when a user performs an action that results in the transmission of information to TWNTY Digital.

For more information about Pipedrive’s data processing and privacy practices, click here: https://www.pipedrive.com/en/privacy .

We are looking forward to your message!

We are looking forward to your message!

For questions, tips and comments we are always at your disposal. Feel free to write to us via our contact form.

For questions, tips and comments we are always at your disposal. Feel free to write to us via our contact form.

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Niklas HoffmeierFounder+49 (0)341 221 796 00

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TWNTY Digital GmbH

Pfaffendorfer Straße 26

04105 Leipzig/Germany

+49 (0)341 221 796 00