Privacy Policy

Responsible Party

Julia Gabriele Wöhr
Klenzestrasse 40
80469 Munich

Email: jw@studiowoehr.com

Impressum

Processing Overview

The following overview summarizes the types of processed data, purposes of processing, and refers to the affected persons.

Types of Processed Data

  • Account data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of Affected Persons

  • Communication partners.
  • Users.

Processing Purposes

  • Communication.
  • Security measures.
  • Reach measurement.
  • Organizational and administrative procedures.
  • Feedback.
  • Profiles with user-related information.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.

Relevant Legal Bases

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

  • Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the legitimate interests pursued by 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 protection of personal data.

National Data Protection Regulations in Germany: In addition to GDPR data protection regulations, national regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (BDSG). The BDSG contains specific 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 transmission, as well as automated individual decision-making including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on GDPR and Swiss DPA Applicability: This privacy notice serves to provide information under both the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, please note that the GDPR terminology is used due to its broader territorial application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "particularly sensitive personal data" used in the Swiss DPA, the GDPR terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" are used. However, the legal meaning of the terms continues to be determined according to the Swiss DPA within the scope of its applicability.

Security Measures

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

The 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, disclosure, availability assurance, and separation of the data. We have also established procedures to ensure the exercise of data subject rights, deletion of data, and responses to data compromise. Furthermore, we consider the protection of personal data already during the development or selection of hardware, software, and processes according to the principle of data protection by design and through privacy-friendly default settings.

Transfer 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 entities, companies, legally independent organizational units, or persons. Recipients of this data may include IT service providers or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and conclude contracts or agreements that serve to protect your data with the recipients of your data.

International Data Transfers

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 disclosure or transfer of data to other persons, entities, or companies, this will only occur in accordance with legal requirements. Subject to explicit consent or contractually or legally required transfer, we only process or allow the processing of data in third countries with a recognized level of data protection, contractual obligation through standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=en). Under the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level for certain companies in the USA as secure through the adequacy decision of July 10, 2023. The list of certified companies and further information about the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you which of our service providers are certified under the Data Privacy Framework within the privacy notices.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or other legal grounds for processing cease to exist. This applies to cases where the original processing purpose no longer exists or the data is no longer needed. Exceptions to this rule exist when legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and deletion of data that specifically applies to certain processing processes.

When there are multiple specifications for the retention period or deletion deadline of data, the longest period always applies.

If a period does not explicitly start on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships under which data is stored, the event triggering the period is the time when the termination or other end of the legal relationship becomes effective.

Data that is no longer needed for the originally intended purpose but must be retained due to legal requirements or other reasons is processed exclusively for the reasons that justify its retention.

Additional Information on Processing Procedures, Processes, and Services:

  • Data Retention and Deletion: The following general periods apply for retention and archiving under 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 (§ 147(1) No. 1 in conjunction with (3) AO, § 14b(1) UStG, § 257(1) No. 1 in conjunction with (4) HGB).
    • 8 years - Accounting documents, such as invoices and cost documents (§ 147(1) No. 4 and 4a in conjunction with (3) sentence 1 AO and § 257(1) No. 4 in conjunction with (4) HGB).
    • 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, operating calculation sheets, calculation documents, price markings, but also payroll accounting documents, insofar as they are not already accounting documents and cash register strips (§ 147(1) No. 2, 3, 5 in conjunction with (3) AO, § 257(1) No. 2 and 3 in conjunction with (4) HGB).
    • 3 years - Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries, based on previous business experience and common industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of data subjects under GDPR: As a data subject under GDPR, you have various rights, which arise in particular from Art. 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 Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes 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 of Access: You have the right to obtain confirmation as to whether relevant data is being processed and to information about this data as well as further information and copy of the data in accordance with legal requirements.
  • Right to Rectification: You have the right, in accordance with legal requirements, 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 relevant data be erased immediately, or alternatively, in accordance with legal requirements, to request 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, commonly used and machine-readable format or to request its transmission to another controller in accordance with legal requirements.
  • Complaint to Supervisory Authority: Without prejudice to any other administrative or judicial remedy, 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 GDPR.

Provision of Online Services and Web Hosting

We process users' data 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 device.

  • Types of data processed: Usage data (e.g., webpage visits and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved); Log data (e.g., logfiles concerning logins or data retrieval or access times). Content data (e.g., text or image messages and posts and information concerning them, such as authorship information or creation time).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (Operation and provision of information systems and technical devices (computers, servers etc.)). Security measures.
  • Storage and deletion: Deletion according to specifications in the section "General Information on Data Storage and Deletion".
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Additional Information on Processing Procedures, Processes, and Services:

  • Collection of Access Data and Logfiles: Access to our online service is logged in the form of "server logfiles". Server logfiles can include the address and name of the accessed webpages and files, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. The server logfiles can be used for security purposes, e.g., to avoid server overload (especially in case of abusive attacks, so-called DDoS attacks) and to ensure server load and stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidential purposes is exempt from deletion until the respective incident is finally clarified.
  • Email Sending and Hosting: The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of recipients and senders as well as other information concerning email sending (e.g., the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that emails are generally not encrypted on the Internet. As a rule, emails are encrypted during transport, 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 take responsibility for the transmission path of emails between the sender and reception on our server; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Content Delivery Network: We use a "Content Delivery Network" (CDN). A CDN is a service that helps deliver content of an online service, especially large media files such as graphics or program scripts, more quickly and securely using regionally distributed servers connected via the Internet; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Use of Cookies

The term "cookies" refers to functions that store information on users' devices and read from them. Cookies can furthermore be used for various purposes, such as functionality, security, and comfort of online services as well as the creation of visitor flow analyses. We use cookies in accordance with legal requirements. For this purpose, we obtain, when necessary, prior consent from users. Consent is not necessary if storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online service. Consent can be revoked at any time. We clearly inform about its scope and which cookies are used.

Notes on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent exists, 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 duration: With regard to storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after closing the device. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Similarly, user data collected with cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), they should assume these are permanent and the storage duration can be up to two years.

General information on withdrawal and objection (opt-out): Users can withdraw their given consent at any time and also declare an objection to processing in accordance with legal requirements, including through their browser's privacy settings.

  • Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Additional Information on Processing Procedures, Processes, and Services:

  • Processing of Cookie Data Based on Consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure serves to obtain, record, manage, and revoke consents, particularly regarding the use of cookies and similar technologies that store, read, and process information on users' devices. As part of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing operations and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid having to repeat the query and to be able to prove consent in accordance with legal requirements. Storage occurs server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information about providers of consent management services is provided, the following general information applies: The duration of consent storage is up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information about the scope of consent (e.g., concerning categories of cookies and/or service providers), and information about the browser, system, and device used; Legal bases: Consent (Art. 6(1)(a) GDPR).

Web Analysis, Monitoring and Optimization

Web analysis (also referred to as "reach measurement") serves to evaluate visitor flows to our online service and can 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, recognize at what time our online service or its functions or content are most frequently used, or invite reuse. We can also understand which areas need optimization.

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

Unless otherwise stated below, profiles can be created for these purposes, i.e., data summarized for a usage process, and information can be stored in a browser or device and then read out. The collected information includes, in particular, visited websites and elements used there, as well as technical information such as the browser used, the computer system, and information about usage times. If users have agreed to the collection of their location data with us or with the providers of the services we use, location data may also be processed.

Furthermore, 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. Generally, no clear user data (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.

Notes 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, 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., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time information, 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 (Creating user profiles). Provision of our online services and user-friendliness.
  • Storage and deletion: Deletion according to specifications 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 can be stored on users' devices for a period of two years.).
  • Security measures: IP masking (pseudonymization of IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Additional Information on Processing Procedures, Processes, and Services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online service based on a pseudonymous user identification number. This identification number contains no unique data such as names or email addresses. It serves to assign analysis information to a device to recognize which content users have accessed within one or various usage processes, which search terms they have used, accessed again, or interacted with our online service. The time and duration of use are also stored, as well as the sources of users referring to our online service and technical aspects of their devices and browsers. Pseudonymous profiles of users with information from the use of various devices are created, where cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Security measures: IP masking (pseudonymization of IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: Data Privacy Framework (DPF); Opt-out options: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for ad display: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (Types of processing and processed data).