**Data Protection** **Introduction** With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on this platform. Status: February 2023 **Table of contents** Introduction Person responsible Overview of processing operations Contact Data Protection Officer Applicable legal basis Transfer and disclosure of personal data Data processing in third countries Use of cookies Provision of the online offer and web hosting Newsletter and electronic notifications Surveys and polls Web analysis, monitoring and optimization Presence in social networks (social media) Plugins and embedded functions and content Deletion of data Modification and updating of the privacy policy Rights of the data subjects **Person responsible** iRights.Lab GmbH Managing Director: Philipp Otto, Dr. Wiebke Glässer Address: Oranienstr. 185, 10999 Berlin, Germany Phone: +49 (0)30 40 36 77 230 Fax: +49 (0)30 40 36 77 260 E-Mail: data protection /at/irights-lab.de Contact Data Protection Officer Attorney Jan Mönikes SCHALAST & PARTNER Attorneys at Law mbB Marienstr. 30 10117 Berlin **Overview of processing** The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects. **Types of data processed** Inventory data (e.g. names, addresses) Content data (e.g. entries in online forms) Contact data (e.g. e-mail addresses, telephone numbers) Meta/communication data (e.g. device information, IP addresses) Usage data (e.g. websites visited, interest in content, access times) **Categories of data subjects** Users (e.g., website visitors, users of online services). **Purposes of processing** Provision of our online offer and user-friendliness Conversion measurement (measuring the effectiveness of marketing measures) Direct marketing (e.g. by e-mail or postal mail) Feedback (e.g. collecting feedback via online form) Interest-based and behavioral marketing Contact requests and communication Profiling (creation of user profiles) Remarketing Reach measurement (e.g. access statistics, recognition of returning visitors) Security measures Tracking (e.g. interest/behavioral profiling, use of cookies) Provision of contractual services and customer service Administration and response to inquiries **Applicable legal bases** In the following, we share the legal bases of the General Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration. Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes. Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b. DSGVO) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject's request. Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data. **National data protection regulations in Germany:** In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. In addition, the provisions of the Telecommunications Telemedia Data Protection Act (TDDSG) apply, in particular to the process of storing and reading information on terminal equipment (Section 25 (1) sentence 1 TTDSG). This primarily covers the processes of data collection and storage. Furthermore, state data protection laws of the individual federal states may apply. **Transmission and disclosure of personal data** In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data. We use the content management system (CMS) of HumHub GmbH & [Co.KG](http://Co.KG) (Johann-Clanze-Straße 28c, 81369 Munich) to manage the content of our website. The CMS provides secure communication facilities between your browser and our server and uses cookies for elementary internet applications. CMS cookies do not collect IP addresses or personal or sensitive information. Information stored by cookies is not sent to HumHub or any third party. Should you have any questions about the CMS, please email [digitalcollective@irights-lab.de](mailto:digitalcollective@irights-lab.de). The platform is hosted on servers at Mittwald: Mittwald CM Service GmbH & Co. KG Königsberger Straße 4-6 32339 Espelkamp Telefon: +49-5772-293-100 Telefax: +49-5772-293-333 Further information can be found under: [www.mittwald.de](http://www.mittwald.de) **Data processing in third countries** If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements. Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: [https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).).) **Use of cookies** In order to improve our website and to make its use as optimal as possible, we use cookies. Cookies are small text files that are stored on your own computer when you call up our website and enable the browser you are using to be reassigned. Cookies store information such as the language setting, length of visit to our website or the entries made there as a user. This avoids having to re-enter all the necessary data each time you use the site. **Necessary cookies** These cookies are required to ensure the use of essential services of this website. They are essential for the correct and safe execution of the website and should not be disabled via a plugin (cookie blocker). Legal basis: Legitimate Interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO). **Provision of the online offer and web hosting** In order to provide our online offer securely and efficiently, we use the services of a web hosting provider from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services. The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites. The web space is provided on our behalf by the company Mittwald CM Service GmbH & Co. KG Königsberger Street 4-6 32339 Espelkamp Phone: +49-5772-293-100 Fax: +49-5772-293-333 [www.mittwald.de](http://www.mittwald.de) **Collection of access data and log files** We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability. Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses). Data subjects: Users (e.g., website visitors, users of online services). Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). **Deletion and restriction of processing** We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called "block list") solely for this purpose. The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system. **Notes on legal basis** Electronic notifications are sent as a part of our service as declared in our TC. Further information will only be sent on the basis  of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law. **Contents** Information about us, our services, promotions and offers. Types of data processed: inventory data (e.g. names, addresses), contact data (e-mail addresses), meta/communication data (IP addresses), usage data (e.g. web pages visited, interest in content, access times). Data subjects: Communication partner Purposes of processing: direct marketing (e.g., via e-mail or postal mail) Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). Option to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the above contact options, preferably by e-mail. **Surveys and polls** The surveys and polls we conduct (hereinafter "surveys") are evaluated anonymously, unless otherwise stated. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user's browser or to enable the survey to be resumed with the aid of a temporary cookie (session cookie)) or users have consented to this. **Notes on legal basis** If we ask participants to consent to the processing of their data, this is the legal basis for the processing; otherwise, the processing of participants' data is based on our legitimate interests in conducting an objective survey. Types of data processed: contact data (e.g., email addresses, phone numbers), content data (e.g., input in online forms), usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Data subjects: Communication partners, users (e.g., website visitors, users of online services). Purposes of processing: contact requests and communication, direct marketing (e.g., via email or postal mail), tracking (e.g., interest/behavioral profiling, use of cookies), feedback (e.g., collecting feedback via online form) Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). **Web analysis, monitoring and optimization** Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, e.g. age or gender, as anonymized values. With the help of reach analysis, we can, for example, identify at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization. In addition to web analysis, we may also use test procedures, for example, to test and optimize different versions of our online offering or its components. For these purposes, so-called user profiles may be created and stored in a file (so-called "cookies") or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider. The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) is stored as part of web analysis, A/B testing and optimization, but pseudonyms are. This means that both we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures. **Notes on legal basis** Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy. Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses). Data subjects: Users (e.g., website visitors, users of online services). Purposes of processing: reach measurement (e.g., access statistics, recognition of returning visitors), tracking (e.g., interest/behavioral profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles) Security measures: IP masking (pseudonymization of the IP address). Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). **International presence and Social Media** The platform is open for an international audience. Registered users may access the platform from non-European countries. In addition, content from the platform can be shared via social media. We would like to point out that this may involve the processing of user data outside the area of the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them). For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks. In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us. Types of data processed: inventory data (e.g., names, addresses), contact data (e.g., e-mail addresses, telephone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses). Data subjects: Users (e.g., website visitors, users of online services). Purposes of processing: contact requests and communication, tracking (e.g., interest/behavioral profiling, use of cookies), remarketing Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). **Services used and service providers** LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: [https://www.linkedin.com;](https://www.linkedin.com;) privacy policy: [https://www.linkedin.com/legal/privacy-policy;](https://www.linkedin.com/legal/privacy-policy;) opt-out: [https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.](https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.) Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; privacy policy: [https://twitter.com/de/privacy,](https://twitter.com/de/privacy,) (settings) [https://twitter.com/personalization.](https://twitter.com/personalization.) Facebook: Social network; service provider: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: [https://facebook.com;](https://facebook.com;) Privacy policy: [https://www.facebook.com/help/568137493302217.](https://www.facebook.com/help/568137493302217.) **Plugins and embedded functions and content** We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content"). The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymized information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources. **Notes on legal basis** If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy. Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail addresses, telephone numbers), content data (e.g. entries in online forms). Data subjects: Users (e.g., website visitors, users of online services), communication partners. Purposes of processing: provision of our online offer and user-friendliness, provision of contractual services and customer service, security measures, administration and response to inquiries, contact requests and communication, direct marketing (e.g. by e-mail or postal mail), tracking (e.g. interest/behavior-based profiling, use of cookies), interest-based and behavior-based marketing, profiling (creation of user profiles) Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). **Services used and service providers** YouTube-Videos: Videoinhalte; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Webseite: [https://www.youtube.com;](https://www.youtube.com;) Datenschutzerklärung: [https://policies.google.com/privacy;](https://policies.google.com/privacy;) Widerspruchsmöglichkeit (Opt-Out): Opt-Out-Plugin: [https://tools.google.com/dlpage/gaoptout?hl=de,](https://tools.google.com/dlpage/gaoptout?hl=de,) Einstellungen für die Darstellung von Werbeeinblendungen: [https://adssettings.google.com/authenticated.](https://adssettings.google.com/authenticated.) YouTube-Videos: Videoinhalte; Dienstanbieter: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Mutterunternehmen: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Webseite: [https://www.youtube.com;](https://www.youtube.com;) Datenschutzerklärung: [https://policies.google.com/privacy;](https://policies.google.com/privacy;) Widerspruchsmöglichkeit (Opt-Out): Opt-Out-Plugin: [https://tools.google.com/dlpage/gaoptout?hl=de,](https://tools.google.com/dlpage/gaoptout?hl=de,) Einstellungen für die Darstellung von Werbeeinblendungen: [https://adssettings.google.com/authenticated.](https://adssettings.google.com/authenticated.) Mass notification: provider: Cuzy.App, 6 Impasse de la Vigne, 31320 Auzeville-Tolosane, France [https://www.cuzy.app/](https://www.cuzy.app/); privacy policy: [https://www.cuzy.app/privacy-policy-terms-and-conditions-of-sale/](https://www.cuzy.app/privacy-policy-terms-and-conditions-of-sale/) JitsiMeet: 8x8, Inc. 675 Creekside Way, Campbell, CA 95008, USA, [https://meet.jit.si/](https://meet.jit.si/); privacy policy: [https://jitsi.org/meet-jit-si-privacy/](https://jitsi.org/meet-jit-si-privacy/) LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: [https://www.linkedin.com;](https://www.linkedin.com;) privacy policy: [https://www.linkedin.com/legal/privacy-policy;](https://www.linkedin.com/legal/privacy-policy;) opt-out: [https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.](https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.) Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; privacy policy: [https://twitter.com/de/privacy,](https://twitter.com/de/privacy,) (settings) [https://twitter.com/personalization.](https://twitter.com/personalization.) Facebook: Social network; service provider: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: [https://facebook.com;](https://facebook.com;) Privacy policy: [https://www.facebook.com/help/568137493302217.](https://www.facebook.com/help/568137493302217.) **Deletion of data** The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person. Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration. Modification and updating of the data protection declaration We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification. If we provide addresses and contact information of companies and organizations in this privacy statement, we ask you to note that the addresses may change over time and to check the information before contacting us. Rights of the data subjects As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 of the GDPR: Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing. Right to withdraw consent: You have the right to revoke any consent given at any time. Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements. Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified. Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data. Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transfer to another controller. Complaint to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.