Question 1

Types of processed data

Accepted Answer

Inventory data (e.g., names, addresses).
Contact data (e.g., email, phone numbers).
Content data (e.g., text inputs, photographs, videos).
Usage data (e.g., visited websites, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses).

Question 2

Categories of affected individuals

Accepted Answer

Visitors and users of the online offering (Hereinafter, we also collectively refer to the affected individuals as "users").

Question 3

Purpose of processing

Accepted Answer

- Provision of the online offering, its features, and content.
- Responding to contact inquiries and communicating with users.
- Security measures.
- Reach measurement/marketing.

Question 4

Used Terminology

Accepted Answer

"Personal data" refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more specific factors expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term encompasses a wide range of activities involving data.

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

"Profiling" refers to 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 person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

The term "Controller" refers to 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" refers to a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

Question 5

Relevant Legal Bases

Accepted Answer

In accordance with Article 13 of the GDPR, we inform you about the legal bases for our data processing activities. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 of the GDPR. The legal basis for processing data for the performance of our services, carrying out contractual measures, and responding to inquiries is Article 6(1)(b) of the GDPR. The legal basis for processing data to fulfill our legal obligations is Article 6(1)(c) of the GDPR. The legal basis for processing data to protect our legitimate interests is Article 6(1)(f) of the GDPR. In cases where the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) of the GDPR serves as the legal basis.

Question 6

Security Measures

Accepted Answer

In accordance with Article 32 of the GDPR, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. These measures take into account the state of the art, the implementation costs, the nature, scope, context, and purposes of the processing, as well as the likelihood and severity of the risks to the rights and freedoms of individuals.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, disclosure, availability, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and the response to data breaches. We also consider data protection measures in the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Article 25 of the GDPR).

Question 7

Collaboration with Processors and Third Parties

Accepted Answer

If, in the course of our processing, we disclose data to other individuals or companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, we do so only based on a legal permission (e.g., if the data transmission to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Article 6(1)(b) of the GDPR), if you have given your consent, if a legal obligation provides for it, or based on our legitimate interests (e.g., when using agents, web hosts, etc.).

If we engage third parties to process data on the basis of a so-called "data processing agreement," this is done in accordance with Article 28 of the GDPR.

Question 8

Transfers to Third Countries

Accepted Answer

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 using third-party services or disclosing/transferring data to third parties, it will only be done if it is necessary for the fulfillment of our pre-contractual or contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we will process or have the data processed in a third country only if the special requirements of Articles 44 and following of the GDPR are met. This means that the processing is carried out, for example, on the basis of specific guarantees, such as the officially recognized determination of an adequate level of data protection corresponding to the EU (e.g., for the USA through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

Question 9

Rights of the Data Subjects

Accepted Answer

You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and to request access to this data, as well as further information and a copy of the data in accordance with Article 15 of the GDPR.

According to Article 16 of the GDPR, you have the right to request the completion of incomplete personal data or the rectification of inaccurate personal data concerning you.

You have the right, according to Article 17 of the GDPR, to request the erasure of personal data concerning you without undue delay, or alternatively, to request the restriction of processing according to Article 18 of the GDPR.

You have the right to receive the personal data concerning you that you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit this data to another controller according to Article 20 of the GDPR.

Furthermore, according to Article 77 of the GDPR, you have the right to lodge a complaint with the supervisory authority.

Question 10

Right to Withdraw Consent

Accepted Answer

You have the right to withdraw your consent granted under Art. 7(3) of the GDPR with effect for the future.

Question 11

Right to Object

Accepted Answer

You can object to the future processing of data concerning you in accordance with Art. 21 of the GDPR at any time. The objection can be made in particular against processing for direct marketing purposes.

Question 12

Cookies and Right to Object to Direct Marketing

Accepted Answer

"Cookies" are small files that are stored on users' computers. Different information can be stored within 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 offering. Temporary cookies, or "session cookies" or "transient cookies," are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can, for example, store the contents of a shopping cart in an online store or a login status. "Permanent" or "persistent" cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it again after several days. Likewise, such a cookie can store the interests of users that are used for measuring reach or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if only their cookies are involved, 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 disable the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. The exclusion of cookies can lead to functional limitations of this online offering.

A general objection to the use of cookies for online marketing purposes, especially in the case of tracking, can be declared on 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 disabling them in the browser settings. Please note that in this case, not all functions of this online offering may be fully usable.

Question 13

Deletion of Data

Accepted Answer

The data processed by us will be deleted or restricted in processing in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and there are no legal retention obligations preventing their deletion. If the data is not deleted because it is required for other purposes permitted by law, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

According to legal requirements in Germany, data is stored for a period of 10 years in particular in accordance with Sections 147(1) AO, 257(1) No. 1 and 4, 4 HGB (books, records, management reports, booking vouchers, commercial books, documents relevant for taxation, etc.), and for 6 years in accordance with Section 257(1) No. 2 and 3, 4 HGB (commercial letters).

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

Question 14

Brokerage Services

Accepted Answer

We process the data of our customers, clients, and interested parties (collectively referred to as "customers") in accordance with Art. 6(1)(b) of the GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this regard, the type, scope, purpose, and necessity of their processing, are determined by the underlying mandate. This generally includes inventory and master data of the customers (name, address, etc.), as well as contact details (email address, telephone, etc.), contract data (content of the engagement, fees, durations, information about the companies/insurers/services being brokered), and payment data (commissions, payment history, etc.). Furthermore, we may process information about the characteristics and circumstances of individuals or their owned assets if it is relevant to our mandate. This may include information about personal life circumstances, movable or immovable assets.

As part of our engagement, it may also be necessary for us to process special categories of data in accordance with Art. 9(1) of the GDPR, particularly information about a person's health. For this purpose, if necessary, we obtain explicit consent from the customers in accordance with Art. 6(1)(a), Art. 7, Art. 9(2)(a) of the GDPR.

If required for the fulfillment of the contract or by law, we disclose or transmit customer data to providers of the brokered services/properties, insurers, reinsurers, broker pools, technical service providers, other service providers such as cooperating associations, as well as financial service providers, banks, investment companies, social security institutions, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen, and the Federal Financial Supervisory Authority (BaFin). Furthermore, we may engage subcontractors, such as sub-brokers. We obtain consent from the customers if their consent is required for disclosure/transmission (which may be the case, for example, for special categories of data under Art. 9 of the GDPR).

The deletion of data takes place after the expiration of statutory warranty and similar obligations, whereby the necessity of data retention is reviewed every three years. The statutory retention obligations also apply.

In the case of legal archiving obligations, deletion occurs upon their expiration. Particularly under German law, consultation protocols in the insurance and financial industry are subject to a 5-year retention period, broker closing notes are retained for 7 years, and broker agreements are retained for 5 years, while general commercial documents are retained for 6 years and tax-relevant documents are retained for 10 years.

Question 15

Contacting Us

Accepted Answer

When contacting us (e.g., via contact form, email, telephone, or social media), the user's information is processed for the purpose of handling the contact request and its fulfillment in accordance with Art. 6(1)(b) (in the context of contractual/pre-contractual relationships) and Art. 6(1)(f) (other inquiries) of the GDPR. The user's information may be stored in a customer relationship management system (CRM system) or a comparable request organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years. Furthermore, the statutory archiving obligations apply.

Question 16

Hosting and Email Communication

Accepted Answer

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services, and technical maintenance services that we use for the operation of this online offering.

In this context, 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 offering based on our legitimate interests in providing an efficient and secure online offering in accordance with Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Question 17

Collection of Access Data and Log Files

Accepted Answer

We, or our hosting provider, collect data based on our legitimate interests in accordance with Art. 6(1)(f) GDPR, 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 accessed website, file, date and time of access, transferred data volume, 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.

For security reasons (e.g., to investigate misuse or fraudulent activities), log file information is stored for a maximum of 7 days and then deleted. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the respective incident is finally clarified.

Question 18

Google Tag Manager

Accepted Answer

Google Tag Manager is a solution that allows us to manage website tags (including integrating Google Analytics and other Google marketing services into our online offering) through an interface. The Tag Manager itself (which implements the tags) does not process personal data of users. Regarding the processing of users' personal data, please refer to the information about Google services. Usage policy: https://www.google.com/intl/de/tagmanager/use-policy.html.(https://www.google.com/intl/de/tagmanager/use-policy.html)

Question 19

Google Analytics

Accepted Answer

Based on our legitimate interests (i.e., interest in analyzing, optimizing, and running our online offering economically in accordance with Art. 6(1)(f) GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the users' use of the online offering is usually transmitted to and stored on a server operated by Google in the United States.

Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

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

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

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly. Furthermore, users can prevent Google from collecting and processing the data generated by the cookie and related to their use of the online offering by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

For more information about Google's data usage, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated).

The users' personal data will be deleted or anonymized after 14 months.

Question 20

Google AdWords and Conversion Tracking

Accepted Answer

Based on our legitimate interests (i.e., interest in analyzing, optimizing, and running our online offering economically in accordance with Art. 6(1)(f) GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing method Google "AdWords" to place advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a potential interest in the ads. This allows us to present advertisements for and within our online offering in a more targeted manner, only showing users ads that potentially match their interests. For example, if a user is shown ads for products they have previously shown interest in on other online offerings, this is referred to as "remarketing." For this purpose, when our website and other websites that are active in the Google advertising network are accessed, Google immediately executes a code from Google and integrates so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") into the website. With their help, an individual cookie, i.e., a small file, is stored on the user's device (instead of cookies, comparable technologies can also be used). This file records which websites the user has visited, which content they are interested in, which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit duration, and further information about the use of the online offering.

Furthermore, we receive an individual "conversion cookie." The information obtained using the cookie is used by Google to create conversion statistics for us. However, we only receive the anonymous total number of users who clicked on our ad and were redirected to a page equipped with a conversion tracking tag. We do not receive any information that personally identifies users.

The user data is processed pseudonymously within the scope of the Google advertising network. This means that Google does not store and process the names or email addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. From Google's perspective, the ads are not managed and displayed for an identified individual but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google's servers in the United States.

For more information about Google's data usage, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated)(https://adssettings.google.com/authenticated).

Question 21

Google DoubleClick

Accepted Answer

Based on our legitimate interests (i.e., interest in analyzing, optimizing, and running our online offering economically in accordance with Art. 6(1)(f) GDPR), we use the services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing method Google "Doubleclick" to place advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.). DoubleClick stands out by displaying ads in real-time based on users' presumed interests. This allows us to present ads for and within our online offering in a more targeted manner, only showing users ads that potentially match their interests. For example, if a user is shown ads for products they have previously shown interest in on other online offerings, this is referred to as "remarketing." For this purpose, when our website and other websites that are active in the Google advertising network are accessed, Google immediately executes a code from Google and integrates so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") into the website. With their help, an individual cookie, i.e., a small file, is stored on the user's device (instead of cookies, comparable technologies can also be used). This file records which websites the user has visited, which content they are interested in, which offers the user has clicked on, as well as technical information about the browser and operating system, referring websites, visit duration, and further information about the use of the online offering.

The IP address of the users is also collected, whereby it is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only transmitted in full to a Google server in the USA and shortened there in exceptional cases. The aforementioned information may also be combined by Google with information from other sources. If the user subsequently visits other websites, they may be shown tailored ads based on their presumed interests, using their user profile as a basis.

The user data is processed pseudonymously within the scope of the Google advertising network. This means that Google does not store and process the names or email addresses of users but processes the relevant data cookie-related within pseudonymous user profiles. From Google's perspective, the ads are not managed and displayed for an identified individual but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users by Google marketing services is transmitted to Google and stored on Google's servers in the United States.

For more information about Google's data usage, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for displaying advertisements by Google (https://adssettings.google.com/authenticated)(https://adssettings.google.com/authenticated).

Question 22

Online presence on social media

Accepted Answer

We maintain online presences within social networks and platforms to communicate with active customers, prospects, and users and to provide them with information about our services.

We would like to point out that user data may be processed outside the European Union. This may pose risks for users because, for example, the enforcement of user rights could be more difficult. Regarding US providers certified under the Privacy Shield, we would like to inform you that they commit to complying with EU data protection standards.

Furthermore, user data is typically processed for market research and advertising purposes. For example, user profiles can be created based on usage behavior and resulting user interests. These user profiles can then be used to display ads within and outside the platforms that presumably correspond to the users' interests. For these purposes, cookies are usually stored on users' computers, in which their usage behavior and interests are stored. Additionally, data can be stored in user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and logged in).

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

For detailed information on the respective processing activities and opt-out options, please refer to the linked information provided by the providers.

In the case of information requests and the exercise of user rights, we would like to emphasize that these can be most effectively addressed with the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need assistance, 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.

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

Question 23

Integration of third-party services and content

Accepted Answer

Within our online offering, we rely on content or service offerings from third-party providers based on our legitimate interests (i.e., interest in analyzing, optimizing, and operating our online offering economically, within the meaning of Art. 6(1)(f) GDPR). These third-party providers may include content and services such as videos or fonts (collectively referred to as "content").

This always requires that the third-party providers of this content perceive the IP address of the users because they cannot send the content to their browsers without the IP address. The IP address is therefore necessary for the display of this content. We strive to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users' device and may contain technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.

YouTube:
We embed videos from the platform "YouTube," provided by 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 fonts ("Google Fonts") provided by 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 embed maps from the service "Google Maps," provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include IP addresses and user location data, which, however, are not collected without their consent (usually within 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.

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