In the following, we will inform you in accordance with the legal requirements of data protection law (especially in accordance with BDSG n.F. and the European General Data Protection Regulation “DS-GVO”) about the nature, scope and purpose of the processing of personal data by our company. This Privacy Policy also applies to our websites and social media profiles. With regard to the definition of terms such as “personal data” or “processing”, we refer to Art. 4 DS-BER.

Name and contact details of the responsible person (s)

Our Responsible (hereinafter “Responsible”) i.S.d. Art. 4 Zif. 7 DS-GMO is:

Lange Straße 23

20359 Hamburg/Germany

Managing Director Rainer Holtorff

Tel: +49 40 380 47 423


Types of data, purposes of processing and categories of data subjects

Below we inform you about the nature, scope and purpose of the collection, processing and use of personal data.

Types of data we process

Usage data (access times, websites visited, etc.), contact data (telephone number, e-mail, fax, etc.), content data (text input, videos, photos, etc.), communication data (IP address, etc.),

Purposes of processing according to Art. 13 para. 1 c) DS-GVO

Optimize Website Technically and Economically, Provide Easy Access to Website, Optimize and Statistically Evaluate Our Services, Support Website Commercial Use, Improve User Experience, Design User-Friendly Website, Economic Operation of Advertising and Website, Marketing / Sales / Advertising, Compilation of Statistics, Avoidance SPAM and abuse, customer service and customer care, handling contact requests, providing websites with features and content, security measures, uninterrupted, secure operation of our website,

Categories of data subjects according to Art. 13 para. 1 e) of the DS-GVO

Visitors / users of the website, customers, interested parties,

The persons concerned are collectively referred to as “users”.

Legal basis for the processing of personal data

Below we inform you about the legal bases of the processing of personal data:

If we have obtained your consent to the processing of personal data, Art. 6 (1) sentence 1 lit. a) DS-GMO Legal basis.

If the processing is necessary to fulfill a contract or to carry out pre-contractual measures, which are carried out at your request, Art. 6 para. 1 sentence 1 lit. b) DS-GMO Legal basis.

If the processing is necessary to fulfill a legal obligation that we are subject to (eg statutory retention requirements), then Art. 6 (1) sentence 1 lit. c) DS-GMO Legal basis.

If processing is necessary to protect the vital interests of the data subject or another natural person, Art. 6 para. 1 sentence 1 lit. d) DS-GMO Legal basis.

If the processing is necessary for the protection of our or the legitimate interests of a third party and your interests or fundamental rights and freedoms do not predominate in this regard, then Art. 6 para. 1 sentence 1 lit. f) DS-GMO Legal basis.

Disclosure of personal data to third parties and processors

Without your consent, we generally do not pass on data to third parties. If this is the case, then the transfer takes place on the basis of the aforementioned legal basis, e.g. when passing on data to online payment providers for performance of a contract or by court order or for a legal obligation to disclose the data for the purposes of law enforcement, security or enforcement of intellectual property rights.

We also use processors (external service providers, for example, to host our websites and databases) to process your data. If data are passed on to the processor by order processing, this is always done in accordance with Art. 28 of the GDPR. We select our processors carefully, monitor them regularly and have given us the right to give instructions regarding the data. In addition, the processors must have taken appropriate technical and organizational measures and the data protection rules in accordance with Art. BDSG n.F. and DS-GMOs

Data transmission to third countries

The adoption of the basic European data protection regulation (DS-GVO) has created a uniform basis for data protection in Europe. Your data will therefore be processed primarily by companies for which DS-GVO applies. If the processing takes place through services of third parties outside the European Union or the European Economic Area, they must fulfill the special requirements of Art. 44 et seq. DS-GVO. This means that processing takes place on the basis of special guarantees, such as the EU Commission’s officially acknowledged level of data protection or the observance of officially recognized special contractual obligations, the so-called “standard contractual clauses”. In US companies, submission to the Privacy Shield, the EU-US data protection agreement, meets these requirements.

Deletion of data and storage duration

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as the purpose for the storage is omitted, unless their further storage is required for evidence or contrary to legal storage requirements. These include, for example, commercial requirements for the storage of business letters pursuant to Section 257 (1) HGB (6 years) and tax-related retention obligations pursuant to Section 147 (1) AO von Beleg (10 years). If the prescribed retention period expires, your data will be blocked or deleted, unless storage is still required for a contract or fulfillment.

Existence of automated decision-making

We do not use automatic decision making or profiling.

Provision of our website and creation of log files

If you only use our website for informational purposes (ie no registration and no other transmission of information), we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data: • IP address;

Internet service provider of the user;
Date and time of the call;
browser type;
language and browser version;
Content of the call;
time zone;
access status / HTTP status code;
amount of data;
Websites from which the request comes;
Operating system.

There is no storage of this data together with other personal data of you.

These data serve the purpose of the user-friendly, functional and safe delivery of our website to you with functions and contents as well as their optimization and statistical evaluation.

The legal basis for this is our legitimate interest in the processing of data according to Art. 6 para. 1 p. 1 lit. f) DS-GMO.

For security reasons, we store this data in server log files for the retention period of 90 days. After this period, they will be automatically deleted, unless we require their retention for evidence in attacks on the server infrastructure or other violations.


We use so-called cookies when you visit our website. Cookies are small text files that your Internet browser stores and saves on your computer. When you visit our website again, these cookies provide information to automatically recognize you. The information obtained in this way serves the purpose of optimizing our web offers, both technically and economically, and to provide you with easier and safer access to our website. We inform you about this when you visit our website by means of a reference to our privacy policy on the use of cookies for the purposes mentioned above and how you can contradict or prevent their storage (“opt-out”). Our website uses session cookies, persistent cookies and third-party cookies:

Session Cookies: We use so-called “cookies” to recognize multiple uses of an offer by the same user (for example, if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information obtained in this way serves to optimize our offers and to give you easier access to our site. If you close the browser or log out, the session cookies will be deleted.

Persistent cookies: These are automatically deleted after a specified period, which may differ depending on the cookie. In the security settings of your browser, you can delete the cookies at any time.

Third party cookies (third party cookies): According to your wishes, you can change your browser settings

The legal basis of this processing is Art. 6 para. 1 p. Lit. b) DS-GVO, if the cookies are used to initiate a contract, e.g. otherwise we have a legitimate interest in the effective functionality of the website, so that in the case of Art. 6 para. 1 sentence 1 lit. f) DS-GVO legal basis.

Opposition and opt-out: You can generally prevent the storage of cookies on your hard disk by selecting “Do not accept cookies” in your browser settings. However, this can result in a functional restriction of our offers. You may opt-out of third-party cookies for advertising purposes through this American website ( or this European website ( / praferenzmanagement /) contradict.

Contact by contact form / E-Mail / Fax / Post

When contacting us via contact form, fax, mail or e-mail your details will be processed for the purpose of processing the contact request.

Legal basis for the processing of the data is in the presence of a consent of you Art. 6 para. 1 p. 1 lit. a) DS-GMO. The legal basis for the processing of data transmitted in the course of a contact request or e-mail, letter or fax is Article 6 (1) sentence 1 lit. f) DS-GMO. The person in charge has a legitimate interest in the processing and storage of the data in order to be able to answer inquiries from the users, to secure evidence for liability reasons and, if necessary, to fulfill his statutory retention requirements for business letters. If the contact is aimed at the conclusion of a contract, additional legal basis for processing is Art. 6 para. 1 sentence 1 lit. b) DS-GMO.

We can save your details and contact requests in our Customer Relationship Management System (“CRM System”) or a comparable system.

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. For the personal data from the input form of the contact form and those sent by e-mail, this is the case when the respective conversation with you is over. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified. Requests from users who have an account or contract with us, we save until the expiration of two years after the contract termination. In the case of legal archiving obligations, the deletion takes place after its expiration: end of commercial law (6 years) and tax law (10 years) retention obligation.

At any time, you have the option of obtaining consent in accordance with Art. 6 para. 1 sentence 1 lit. a) to revoke the GDPR for the processing of personal data. If you contact us by e-mail, you may object to the storage of your personal data at any time.

Contact by phone

When contacting us by phone, your telephone number will be processed to process the contact request and its processing and temporarily stored or displayed in the RAM / cache of the telephone / display. The storage is made for reasons of liability and security in order to be able to prove the call as well as for economic reasons to enable a callback. In the case of unauthorized advertising calls, we block the phone numbers.

The legal basis for processing the telephone number is Art. 6 (1) sentence 1 lit. f) DS-GMO. If the contact is aimed at the conclusion of a contract, additional legal basis for the processing is Art. 6 para. 1 lit. b) DS-GMO.

The device cache stores the calls for days and overwrites or deletes old data successively; when the device is disposed of, all data is deleted and the memory is destroyed. Blocked phone numbers are checked annually for the need for blocking.

You can prevent the phone number from being displayed by calling with the phone number suppressed.


You can subscribe to our newsletter with your voluntary consent by entering your e-mail address. Only this is mandatory. The indication of further data is voluntary and serves only the purpose of a personal address. We use the so-called “double opt-in procedure” for registration. After registering with your e-mail, you will receive an e-mail from us confirming your registration with a confirmation link. If you click on this confirmation link, your e-mail will be included in the newsletter mailing list and saved for the purpose of sending e-mails. If you do not click on the confirmation link within 24 hours, your login details will be blocked and automatically deleted after 30 days.

In addition, we log your IP address used during login as well as the date and time of the double opt-in (login and confirmation). The purpose of this storage is fulfillment of legal requirements regarding the proof of your registration as well as the prevention of misuse regarding your e-mail.

As part of your declaration of consent, the content (for example advertised products / services, blog, offers, advertising and topics) of the newsletter will be described concretely.

We currently do not use any shipping service provider for e-mail delivery. Our e-mails are sent directly from our server and do not reach you via third parties (service providers). Therefore, there is no agreement on order processing according to Art. 28 DS-GVO.

When sending the newsletter, we evaluate your user behavior. The newsletters contain so-called “web beacons” or “tracking pixels”, which are called up when the newsletter is opened. For the evaluations, we link the web beacons with your e-mail address and an individual ID. Also in the newsletter received links contain this ID. The data are collected exclusively pseudonymised, so the IDs are not linked to your other personal data, a direct personal reference is excluded. With this data we can determine if and when you have opened the newsletter and which links in the newsletter have been clicked. This serves the purpose of the optimization and statistical evaluation of our newsletter.

Legal basis for the newsletter, success and storage of the e-mail is your consent acc. Art. 6 para. 1 sentence 1 lit. a) DS-GVO in conjunction with § 7 (2) no. 3 UWG and for the recording of consent Art. 6 para. 1 sentence 1 lit. f) DS-GVO, as this serves our legitimate interest of legal proof.

You can object to tracking at any time by clicking on the unsubscribe link at the end of the newsletter. In this case, however, the newsletter reception would also be terminated. If you disable the display of images in your e-mail software, tracking is also not possible. However, this may have limitations in terms of the features of the newsletter, and included images will not be displayed.

You can revoke your consent to the sending of the newsletter at any time. You can exercise the cancellation by clicking on the unsubscribe link at the bottom of the newsletter, sending an e-mail or message to our contact details above. We save your data as long as you have subscribed to the newsletter. After logging off, your data will only be stored anonymously for statistical purposes

Google AdWords with conversion tracking

We use the AdWords Conversion Tracking service (Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA) to promote third party websites by viewing our website. When you click on a Google ad from us, a cookie will be stored in your browser for approximately 30 days. If you then visit our website, we and Google can use the cookie to evaluate whether you have visited our website and which page you have visited with us. About this Google creates a statistic. The full extent of the data processing is unknown to us. The data is also transmitted to the USA and analyzed there. If you are logged in with a Google Account, AdWords will allow the data to be associated with your account. If you do not want this, you must log out before visiting our website. This conversion tracking is for the purpose of analyzing, optimizing and operating our advertising and website.

The legal basis for the processing of your data is our legitimate interest in the analysis, optimization and economic operation of our advertising and website in accordance with Art. 6 (1) sentence 1 lit. f) DS-GMO. Google is certified under the EU-US Privacy Shield: Framework.

You may object to or prevent Google from installing cookies in various ways:

You can prevent the cookies in your browser by the setting “do not accept cookies”, which also includes third-party cookies;

You can disable conversion tracking directly from Google through the link, but this setting will only be in effect until you delete your cookies.

You can view the third-party ads that participate in the About Ads promotional self-help link at for US pages or for EU pages at de / praferenzmanagement / deactivate this setting only if you delete all your cookies;

You can permanently disable cookies through a browser plug-in for Chrome, Firefox, or Internet Explorer at This disabling may result in you being unable to fully use all features of our website.

For more information, please see the Google Privacy Policy at and

Facebook Custom Audiences

We use the “Custom Audiences” remarketing feature of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. Facebook has submitted to the Privacy Shield Agreement ( Framework).

When you visit the social network Facebook or other websites that use this remarketing feature, your interest-based ads (“Facebook Ads”) may appear. We use the remarketing feature to optimize and operate our website and to show you advertisements that interest you and to make our website more user-friendly.

When you visit our website, your browser connects to the Facebook servers. Which data is exactly transferred to Facebook, eludes our knowledge. But Facebook receives the information that you have called up or clicked on a corresponding ad. If you are logged in to Facebook, Facebook can assign this information to your account.

The legal basis for this is our legitimate interest in the processing of data according to Art. 6 para. 1 p. 1 lit. f) DS-GMO.

For processing by Facebook, please read Facebook’s privacy policy at Special information and details about the Facebook pixel and how it works can be found in the Help section of Facebook:

Deactivating the function “Facebook Custom Audiences” is possible for non-logged-in users here [__Facebook Pixel Opt-Out Link of your webpage__] and for logged-in users under this link: = ads #.

For more information about data processing through Facebook, please visit

YouTube videos

We have integrated YouTube videos from on our website using the embedded function, so that they can be accessed directly on our website. YouTube is part of Google Inc., 1600 Amphitheater Parkway, Mountainview, California 94043, USA, EU office: Google D


We have social media plug-ins on our website (based in the EU: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland) as part of the so-called “two-click solution “These are recognized by the Facebook logo” f “or the addition” Like “,” Like “or” Share “.

As soon as you deliberately activate the Facebook plug-in, a connection is made from your browser to the Facebook servers. At the same time, Facebook receives the information, including your IP, that you have accessed our website and transmits this information to Facebook servers in the USA where this information is stored. If you are logged into your account on Facebook, Facebook can assign this information to your account. When using the functions of the plug-in, e.g. By clicking on the “Like” button, this information will also be transferred from your browser to Facebook’s servers in the US, stored there and displayed on your Facebook profile and, if applicable, your friends.

The purpose and scope of the data collection and their further processing and use of the data by Facebook, as well as your rights and options to protect your privacy, you can refer to the privacy policy of Facebook: Data collection on the “Like” button: Your settings regarding the use of your profile data for advertising purposes on Facebook can be managed and contradicted here:

If you log out of Facebook before visiting our website and delete your cookies, no information about your visit to our website will be associated with your profile on Facebook when activating the plug-in.

You can also prevent the Facebook plug-in from being blocked by so-called “Facebook Blockers”, which you can install as an add-on for your browser: Facebook Blocker for Firefox, Chrome and Opera or 1blocker for Safari, iPad and iPhone.

Facebook has submitted to the Privacy Shield, ensuring that European data protection law is respected: framework.

Data protection in applications and in the application process

Applications sent electronically or by post to the person in charge will be processed electronically or manually for the purposes of processing the application process.

We expressly point out that application documents with “special categories of personal data” according to Art. 9 DS-GVO (eg a photo that gives an indication of your ethnic origin, religion or marital status), with the exception of any severe disability, which you wanting to disclose a free decision are undesirable. You should submit your application without this data. This does not affect your candidate chances.

Legal bases for processing are Art. 6 para. 1 p. 1 lit. b) DS-GVO and § 26 BDSG n.F.

If an employment relationship with the applicant is completed after the completion of the application process, the applicant data will be stored in compliance with relevant data protection legislation. If no job is offered to you after completing the application process, your application letter and documents will be deleted 6 months after the cancellation has been sent, in order to be able to satisfy any claims and proof obligations according to AGG.

Rights of the person concerned

Opposition or revocation against the processing of your data

Insofar as the processing is based on your consent pursuant to Art. 6 para. 1 sentence 1 lit. a), Art. 7 DS-GVO, you have the right to revoke your consent at any time. The lawfulness of the processing on the basis of the consent until the revocation is not affected.

Insofar as the processing of your personal data is based on the balance of interests pursuant to Art. 6 para. 1 sentence 1 lit. f) support DS-GMO, you can object to the processing. This is the case if, in particular, the processing is not required to fulfill a contract with you, which we describe in each case in the following description of the functions. In the event of such a disagreement, we ask you to explain the reasons why we should not process your personal data as we have done. In the case of your justified objection, we will examine the situation and will either discontinue or adapt the data processing or point out to you our compelling legitimate reasons on which we continue the processing.

You may object to the processing of your personal data for advertising and data analysis purposes at any time. The right to object can be exercised free of charge. About your advertising conflict you can inform us under the following contact details:

Lange Straße 23

20359 Hamburg

Managing Director: Rainer Holtorff

Tel: +49 40 380 47 432



Right to information

You have the right to ask us for confirmation of your processing of personal data in question. If this is the case, you have a right to information about your personal data stored by us according to Art. 15 DS-GVO. This includes, in particular, the information about the processing purposes, the category of personal data, the categories of recipients to whom your data was or is being disclosed, the planned storage period, the source of their data, if not collected directly from you.

Right to rectification

You have the right to correct inaccurate or complete data according to Art. 16 DS-GVO.

Right to delete

You have a right to delete your stored data according to Art. 17 DS-GVO, unless legal or contractual retention periods or other legal obligations or rights to further storage are contrary to this.

Right to restriction

You have the right to demand a restriction on the processing of your personal data if one of the conditions in Art. 18 para. 1 lit. a) to d) DS-GVO is fulfilled:

If you deny the accuracy of your personal information for a period of time that enables the controller to verify the accuracy of your personal information;
the processing is unlawful and you refuse to delete the personal data and instead demand the restriction of the use of personal data;

the controller no longer needs personal information for the purposes of processing, but you need it to assert, exercise or defend legal claims; or

if you have objected to the processing pursuant to Art. 21 para. 1 DS-GVO and it is not yet certain whether the legitimate reasons of the person responsible prevail over your reasons.

Right to data portability

You have the right of data transferability according to Art. 20 DS-GVO, which means that you can receive the personal data stored about us in a structured, common and machine-readable format or you can request the transfer to another person responsible.

Right to appeal

You have a right to complain to a supervisory authority. As a rule, you can contact the supervisory authority for this purpose, in particular in the Member State of residence, place of work or place of alleged infringement.

data security

In order to protect all personally identifiable information transmitted to us and to ensure that our privacy practices are respected by us as well as our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server over a secure SSL connection is transmitted encrypted.

As of: 29.11.2018

Source: Sample privacy policy of