Privacy Policy | Consulting Germany CX eGbR

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).

The terms used are not gender-specific.

As of August 25, 2025

Preamble
Responsible
Overview of processing
Relevant legal bases
Security
Transfer of personal data
International data transfers
General information on data storage and deletion
Rights of data subjects
Business services
Provision of the online offering and web hosting
Use of cookies
Web analysis, monitoring, and optimization

Responsible

Consulting Germany CX eGbR

Email address: consultinggermany.cx@gmail.com

Overview of processing

The following overview summarizes the types of data processed and the purposes for which they are processed and refers to the data subjects.

Types of data processed

Inventory data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta, communication, and procedural data.
Log data.

Categories of data subjects

Service recipients and clients.
Prospective customers.
Users.
Business and contractual partners.

Purposes of processing

Provision of contractual services and fulfillment of contractual obligations.
Communication.
Security measures.
Reach measurement.
Office and organizational procedures.
Organizational and administrative procedures.
Profiles with user-related information.
Provision of our online offering and user-friendliness.
Information technology infrastructure.
Business processes and business procedures.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or registered office. If more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes.
Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.

Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)

– Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection Against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions 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 transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the applicability of the GDPR and the Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms used in the Swiss DSG, “processing” of “personal data,” “overriding interest” and “sensitive personal data” are used instead of the terms ‘processing’ of “personal data” and “legitimate interest” and “special categories of data” used in the GDPR. However, the legal meaning of the terms continues to be determined in accordance with the Swiss Data Protection Act within the scope of its applicability.

Security

We take appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of the processing, as well as the likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, input, transfer, and backup of the data and ensuring its availability and separation. Furthermore, we have established procedures to ensure that data subjects can exercise their rights, that data is deleted and that responses are made to threats to data. We also take the protection of personal data into account during the development and selection of hardware, software and procedures in accordance with the principle of data protection by design and through data protection-friendly default settings.

Securing online connections with TLS/SSL encryption technology (HTTPS): We use TLS/SSL encryption technology to protect user data transmitted via our online services from unauthorized access. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of personal data

In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. The 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 with the recipients of your data to ensure that your data is protected.

Data transfer within the organization: We may transfer personal data to other departments or units within our organization or grant them access to it. If the data is transferred for administrative purposes, this is based on our legitimate business and economic interests or is necessary to fulfill our contractual obligations or if the data subject has given their consent or if we have legal permission to do so.

International data transfers

Data processing in third countries: If we transfer data to 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 or transferring data to other persons, bodies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the US, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.

This double safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses will serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent, or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there is no longer any legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule apply if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy policy contains additional information on the storage and deletion of data that applies specifically to certain processing operations.

If there are several specifications regarding the storage period or deletion periods for a piece of data, the longest period shall always apply. Data that is no longer required for the original purpose but is retained due to legal requirements or other reasons

will be processed exclusively for the reasons that justify their storage.

Storage and deletion of data: The following general periods apply to storage and archiving in accordance with German law:

10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet, as well as the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).
8 years – Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).
6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant for taxation, e.g., hourly wage slips, operating statement forms, calculation documents, price labels, but also payroll documents, unless they are already accounting documents, and cash register receipts (Section 147 (1) Nos. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) Nos. 2 and 3 in conjunction with (4) HGB).
3 years – Data that is necessary to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 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 concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw your consent at any time.
Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.

Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.

Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request that data concerning you be deleted immediately or, alternatively, in accordance with legal requirements, to request that the processing of the data be restricted.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format or to request that it be transferred to another controller in accordance with legal requirements.
Complaint to a supervisory authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR, without prejudice to any other administrative or judicial remedy.

Business services

We process data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”), within the scope of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners (or pre-contractually), for example to respond to inquiries.

We use this data to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations, and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for administrative tasks associated with these obligations and for company organization. We also process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information, and rights (e.g., for the involvement of telecommunications, transport, and other auxiliary services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or financial authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, within the scope of this privacy policy.

We will inform contractual partners of the data required for the aforementioned purposes before or during data collection, e.g., in online forms, by means of special markings (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. for as long as it must be retained for archiving purposes for legal reasons (e.g. for tax purposes, generally ten years).. We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); Contact data (e.g., postal and email addresses or telephone numbers). Contract data (e.g., subject matter of the contract, term, customer category).
Data subjects: Service recipients and clients; interested parties. Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business management procedures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Provision of the online offer and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

Types of data processed: Usage data (e.g., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved); log data (e.g., log files relating to logins or the retrieval of data or access times). Content data (e.g., textual or pictorial messages and contributions, as well as information relating to them, such as details of authorship or time of creation).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing processes, procedures, and services:

Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a server provider (also known as a “web host”). Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” The server log files may include the address and name of the websites and files accessed, the date and time of access, the amount 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 can be used for security purposes, e.g. to prevent server overload (especially in the event of malicious attacks, so-called DDoS attacks), and to ensure server capacity and stability. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data that must be retained for further storage for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

Email transmission and hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form over the internet. As a rule, emails are encrypted during transmission, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server. Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz/. Data processing agreement: Provided by the service provider.

Use of cookies

The term “cookies” refers to functions that store information on users‘ end devices and read it from them. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online services and to analyze visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance, if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

Information on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their end device (e.g., browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. This allows, for example, the login status to be stored and preferred content to be displayed directly when the user revisits a website. The user data collected using cookies may also be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with the legal requirements, including through their browser’s privacy settings.

Types of data processed: Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, processes, and services:

Processing of cookie data based on consent: We use a consent management solution that obtains the consent of users for the use of cookies or for the procedures and providers specified in the consent management solution. This procedure serves to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read, and process information on users‘ end devices. As part of this procedure, users‘ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers specified in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information about the providers of consent management services is available, the following general information applies: The consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information about the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and device used. Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Compliance: Consent management: Procedure for obtaining, recording, managing, and revoking consent, in particular for the use of cookies and similar technologies for storing, reading, and processing information on users‘ end devices and for processing this information. Service provider: Execution on servers and/or computers under our own responsibility for data protection; Website: https://complianz.io/; Privacy policy: https://complianz.io/legal/. Further information: An individual user ID, language, types of consent, and the time at which consent was given are stored on the server and in a cookie on the user’s device.

Web analysis, monitoring, and optimization

Web analysis (also known as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what times our online offering or its functions or content are used most frequently, or invite users to reuse them. We can also identify areas that require optimization.

In addition to web analysis, we may also use test procedures to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes and information may be stored in a browser or on a device and then read. The information collected includes, in particular, websites visited and elements used there, as well as 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 by us or by the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-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., page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.” Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users‘ devices for a period of two years).
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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