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Privacy policy

Preamble

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

The terms used are not gender-specific.

Last updated: 6 August 2025

Contents

Controller

Yevgenii Gryshaiev
Berghalde 1
69126 Heidelberg

Authorised representatives: Yevgenii Gryshaiev, Petro Bokanov

Email address: yevgenii.gryshaiev@fuvsud.de

Legal notice: https://fuvsud.de/impressum/

Overview of processing

The following overview summarises the types of data processed and the purposes of processing, and identifies the data subjects concerned.

Types of data processed

  • Master data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Metadata, communication and procedural data.
  • Log data.
  • Membership data.

Categories of data subjects

  • Service recipients and clients.
  • Prospective customers or interested parties.
  • Communication partners.
  • Users.
  • Members.
  • Business and contractual partners.
  • Donors.
  • Third parties.

Purposes of processing

  • Provision of contractual services and fulfilment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Organisational and administrative procedures.
  • Feedback.
  • Provision of our online services and user-friendliness.
  • Information technology infrastructure.
  • Collection of donations / fundraising.
  • Public relations and information purposes.
  • Public relations.
  • Business processes and business administration procedures.

Relevant legal bases

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

  • Consent (Article 6(1), first sentence, point (a) GDPR) — The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) GDPR) — Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the data subject’s request prior to entering into a contract.
  • Legal obligation (Article 6(1), first sentence, point (c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Article 6(1), first sentence, point (f) GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, provided these are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).

National data protection provisions in Germany: In addition to the data protection provisions of the GDPR, national data protection rules 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 concerning the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, transfers and automated individual decision-making, including profiling. The data protection laws of individual federal states may also apply.

Note on the applicability of the GDPR and the Swiss FADP: This privacy notice provides information under both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). Please therefore note that the terminology of the GDPR is used for broader territorial applicability and comprehensibility. In particular, the terms used in the GDPR for “processing” of “personal data”, “legitimate interests” and “special categories of data” are used instead of the corresponding Swiss FADP terms “Bearbeitung” of “Personendaten”, “überwiegendes Interesse” and “besonders schützenswerte Personendaten”. However, where the Swiss FADP applies, the legal meaning of these terms continues to be determined by the Swiss FADP.

Security measures

In accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to data, access permissions, input, disclosure, availability and separation of data. We have also established procedures to enable the exercise of data subject rights, the deletion of data and responses to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures, in accordance with the principles of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services against unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are cornerstones of secure data transmission on the internet. These technologies encrypt information transmitted between the website or app and the user’s browser (or between two servers), protecting the data against unauthorised access. TLS, the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. A website secured by an SSL/TLS certificate is indicated by HTTPS in its URL. This signals to users that their data is transmitted securely and in encrypted form.

Rights of data subjects

Data subject rights under the GDPR: As a data subject, you have various rights under the GDPR, arising 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 processing of your personal data based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. Where your personal data is processed for direct marketing, you have the right to object at any time to processing for such marketing, including profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent you have given at any time.
  • Right of access: In accordance with legal requirements, you have the right to request confirmation as to whether relevant data is being processed, access to that data, further information and a copy of the data.
  • Right to rectification: In accordance with legal requirements, you have the right to request completion of your data or rectification of inaccurate data relating to you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that your data be deleted without undue delay or, alternatively, to request restriction of its processing.
  • Right to data portability: In accordance with legal requirements, you have the right to receive data relating to you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you consider that processing of your personal data infringes the GDPR.

Performance of tasks under the statutes or rules of procedure

We process the data of our members, supporters, interested parties, business partners and other persons (collectively “data subjects”) where we have a membership or other business relationship with them, perform our tasks and receive services and contributions. We also process data subjects’ data on the basis of our legitimate interests, for example in connection with administrative tasks or public relations.

The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying membership or contractual relationship, which also determines whether particular data must be provided (we otherwise indicate which data is required).

We delete data that is no longer necessary to fulfil our statutory and business purposes. This is determined by the respective tasks and contractual relationships. We retain data for as long as it may be relevant to handling business transactions and any warranty or liability obligations, on the basis of our legitimate interest in addressing them. We regularly review whether data retention is necessary; otherwise, statutory retention obligations apply.

  • Types of data processed: Master data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, duration, customer category); membership data (e.g. personal details such as name, age, gender, contact details (email address, telephone number), membership number, information on membership fees, participation in events, etc.); payment data (e.g. bank details, invoices, payment history). Content data (e.g. text or image messages and posts, and related information such as authorship or time of creation).
  • Data subjects: Members; interested parties; communication partners; donors. Third parties.
  • Purposes of processing: Communication; organisational and administrative procedures; public relations and information purposes; business processes and business administration procedures. Collection of donations / fundraising.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR); membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR). Legal obligation (Article 6(1), first sentence, point (c) GDPR).

Further information on processing activities, procedures and services:

  • Membership administration: Procedures required for membership administration include recruiting and admitting new members, developing and implementing strategies to retain members, and ensuring effective communication with members. These processes include carefully recording and maintaining membership data, regularly updating member information and managing membership fees, including invoicing and accounting; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR), membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).
  • Fee administration: Processing activities required to manage membership fees include recording fee data after a member joins, tracking fee payments and systematically updating payment status, carrying out payment transactions, processing reminders for overdue payments, reconciling accounts in relation to receivables and liabilities, and keeping the corresponding books and records; Legal bases: Legal obligation (Article 6(1), first sentence, point (c) GDPR), legitimate interests (Article 6(1), first sentence, point (f) GDPR), membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).
  • Events and organisational operations: Planning, conducting and following up events, and the general operation of activities under the statutes. Planning includes collecting and processing participant data, coordinating logistical requirements and setting the event agenda. Conducting events includes managing participant registration, updating participant information during the event, and recording attendance and participant activities. Follow-up includes analysing participant data to evaluate the event’s success, preparing reports and archiving relevant event information. General organisational operations include managing membership data, communicating with members and interested parties, and organising internal meetings and sessions; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR), membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).
  • Public relations: Procedures include producing and distributing information materials, maintaining contact data for press and media relations, and organising and holding press conferences and public events. Producing information materials involves collecting and preparing information for press releases, newsletters, reports and other publications. Distribution takes place through digital and traditional channels, including email lists, websites and social media. Maintaining contact data includes recording and updating media contact details and those of other relevant stakeholders. Organising press conferences and events includes planning and conducting them, managing invitations and coordinating event logistics. Interaction with the media and stakeholders takes place through direct communication with journalists, bloggers and other opinion leaders, answering enquiries and providing information; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR), membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).
  • Collection of donations and fundraising: Procedures include planning and conducting fundraising campaigns, managing donor data and communicating with donors and potential supporters. Campaign planning includes developing strategies, setting goals and selecting fundraising channels. Campaigns are conducted by initiating and implementing specific fundraising activities and collecting donations through online platforms, events and direct approaches. Donor data management includes recording, updating and analysing data to optimise future campaigns. Communication with donors and potential supporters takes place through personalised approaches, thank-you letters and regular updates on project achievements and the use of funds; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR), membership agreement (statutes) (Article 6(1), first sentence, point (b) GDPR).

Payment procedures

Within contractual and other legal relationships, on the basis of statutory obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options. For this purpose, in addition to banks and credit institutions, we use other service providers (collectively “payment service providers”).

Data processed by payment service providers includes master data such as name and address, bank data such as account or credit card numbers, passwords, transaction authentication numbers (TANs) and checksums, and information relating to contracts, amounts and recipients. This information is required to carry out transactions. However, the data entered is processed and stored only by the payment service providers. This means we do not receive account or credit card information, only information confirming payment or reporting that it was unsuccessful. Payment service providers may transmit data to credit reference agencies for identity and creditworthiness checks. Please refer to the payment service providers’ terms and conditions and privacy notices.

Payment transactions are governed by the terms and conditions and privacy notices of the respective payment service providers, available on their websites or transaction applications. We also refer to these for further information and for exercising rights of withdrawal, access and other data subject rights.

  • Types of data processed: Master data (e.g. full name, home address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Service recipients and clients; business and contractual partners. Interested parties.
  • Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business administration procedures.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) GDPR). Legitimate interests (Article 6(1), first sentence, point (f) GDPR).

Further information on processing activities, procedures and services:

  • PayPal: Payment services (technical integration of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxemburg; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.

Provision of online services and web hosting

We process users’ data to provide our online services to them. For this purpose, we process users’ IP addresses, which are necessary to transmit the content and functions of our online services to their browsers or devices.

  • Types of data processed: Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); metadata, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Log data (e.g. log files concerning logins, data retrieval or access times).
  • 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 equipment (computers, servers, etc.)); security measures. Provision of contractual services and fulfilment of contractual obligations.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR).

Further information on processing activities, procedures and services:

  • Collection of access data and log files: Access to our online services is recorded in “server log files”. These may include the addresses and names of pages and files requested, date and time of access, volumes of data transferred, confirmation of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, generally, IP addresses and the requesting provider. Server log files may be used for security purposes, for example to prevent server overload (particularly in the event of malicious attacks known as DDoS attacks), and to ensure appropriate server capacity utilisation and stability; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data that must be retained as evidence is excluded from deletion until the respective incident has been definitively resolved.
  • 1&1 IONOS: Services relating to the provision of information technology infrastructure and associated services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Deutschland; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/.

Use of cookies

“Cookies” refers to functions that store information on users’ devices and read information from them. Cookies may serve different purposes, such as the functionality, security and convenience of online services, and analysis of visitor traffic. We use cookies in accordance with legal requirements. Where required, we obtain users’ consent in advance. Where consent is not required, we rely on our legitimate interests. This applies where storing and reading information is essential to provide expressly requested content and functions, such as saving settings and ensuring the functionality and security of our online services. Consent may be withdrawn at any time. We clearly explain its scope and which cookies are used.

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

Storage period: The following types of cookies are distinguished by storage duration:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device application (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device application is closed. For example, login status can be saved and preferred content displayed directly when the user returns to a website. User data collected using cookies may also be used for audience measurement. Unless we explicitly inform users of the type and storage duration of cookies (e.g. when obtaining consent), they should assume that the cookies are persistent and may be stored for up to two years.

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

  • Types of data processed: Metadata, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR). Consent (Article 6(1), first sentence, point (a) GDPR).

Further information on processing activities, procedures and services:

  • Processing cookie data on the basis of consent: We use a consent management solution to obtain users’ consent to the use of cookies or to the procedures and providers specified within that solution. This procedure serves to obtain, record, manage and withdraw consent, particularly regarding cookies and comparable technologies used to store, read and process information on users’ devices. As part of this procedure, users’ consent is obtained for the use of cookies and related information processing, including the specific processing activities and providers named in the consent management procedure. Users can also manage and withdraw their consent. Declarations of consent are stored to avoid asking again and to provide proof of consent as required by law. Storage takes place on the server and/or in a cookie (“opt-in cookie”) or using comparable technologies, so that consent can be assigned to a specific user or device. Unless specific information about consent management service providers is provided, the following general information applies: consent is stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on its scope (e.g. relevant categories of cookies and/or service providers), and information about the browser, system and device used; Legal bases: Consent (Article 6(1), first sentence, point (a) GDPR).

Contact and enquiry management

When you contact us (e.g. by post, contact form, email, telephone or social media), and in the context of existing user and business relationships, we process the information provided by enquirers insofar as necessary to respond to enquiries and any requested measures.

  • Types of data processed: Master data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts, and related information such as authorship or time of creation); usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Metadata, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via an online form). Provision of our online services and user-friendliness.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR). Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) GDPR).

Further information on processing activities, procedures and services:

  • Contact form: When you contact us through our contact form, by email or through other communication channels, we process the personal data provided to answer and handle the respective enquiry. This generally includes information such as name, contact details and any further information provided to us that is necessary to handle the enquiry appropriately. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual enquiries (Article 6(1), first sentence, point (b) GDPR), legitimate interests (Article 6(1), first sentence, point (f) GDPR).

Newsletters and electronic notifications

We send newsletters, emails and other electronic notifications (collectively “newsletters”) only with recipients’ consent or on a statutory basis. Where newsletter content is specified during registration, that content determines the scope of users’ consent. Usually, providing your email address is sufficient to subscribe to our newsletter. However, to offer a personalised service, we may ask for your name for a personal greeting in the newsletter, or for additional information if necessary for the newsletter’s purpose.

Deletion and restriction of processing: On the basis of our legitimate interests, we may store unsubscribed email addresses for up to three years before deleting them, in order to prove that consent was previously given. Processing of this data is restricted to the purpose of potentially defending against claims. An individual request for deletion may be made at any time, provided the previous existence of consent is also confirmed. Where we are obliged to respect objections permanently, we reserve the right to store the email address in a suppression list (“blocklist”) solely for this purpose.

The registration procedure is logged on the basis of our legitimate interests in demonstrating that it was carried out correctly. Where we engage a service provider to send emails, we do so on the basis of our legitimate interests in an efficient and secure mailing system.

Content:

Information about us, our services, campaigns and offers.

  • Types of data processed: Master data (e.g. full name, home address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); metadata, communication and procedural data (e.g. IP addresses, timestamps, identification numbers, persons involved). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal bases: Consent (Article 6(1), first sentence, point (a) GDPR).
  • Right to object (opt-out): You may unsubscribe from our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find an unsubscribe link at the end of each newsletter, or you can use one of the contact methods specified above, preferably email.

Further information on processing activities, procedures and services:

  • Measuring opening and click rates: Newsletters contain a “web beacon”, a pixel-sized file retrieved from our server, or from the mailing service provider’s server if we use one, when the newsletter is opened. This retrieval initially collects technical information, such as information about your browser and system, as well as your IP address and the time of retrieval. This information is used to improve our newsletter technically, based on technical data or target groups and their reading behaviour, using retrieval locations (which can be determined from the IP address) or access times. The analysis also establishes whether and when newsletters are opened and which links are clicked. This information is assigned to individual newsletter recipients and stored in their profiles until deletion. The analyses help us understand users’ reading habits and tailor our content to them or send different content according to their interests. Measurement of opening and click rates and storage of measurement results in users’ profiles Legal bases: Consent (Article 6(1), first sentence, point (a) GDPR).

Presences on social networks (social media)

We maintain online presences on social networks and process user data in this context in order to communicate with users active there or provide information about us.

Please note that user data may be processed outside the European Union. This may create risks for users, for example because enforcing their rights may be more difficult.

Furthermore, user data on social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behaviour and the interests inferred from it. These profiles may in turn be used to display advertisements within and outside the networks that are presumed to match users’ interests. Cookies are therefore generally stored on users’ computers to record their behaviour and interests. In addition, usage profiles may contain data independently of the devices used, particularly where users are members of the respective platforms and are logged in.

For a detailed description of the respective forms of processing and opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.

For requests for information and the exercise of data subject rights, we also note that these can be most effectively asserted against the providers. Only they have access to users’ data and can directly take appropriate measures and provide information. If you nevertheless need assistance, you can contact us.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts, and related information such as authorship or time of creation). Usage data (e.g. page views and time spent, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; feedback (e.g. collecting feedback via an online form). Public relations.
  • Retention and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR).

Further information on processing activities, procedures and services:

  • Instagram: Social network enabling the sharing of photos and videos, commenting on and favouriting posts, sending messages, and following profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the Facebook social network — Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection (but not further processing) of data relating to visitors to our Facebook page (“fan page”). This data includes information about the types of content users view or interact with, or actions they take (see “Things you and others do and provide” in Facebook’s data policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in Facebook’s data policy: https://www.facebook.com/privacy/policy/). As explained in Facebook’s data policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services known as “Page Insights” to page operators, enabling them to understand how people interact with their pages and associated content. We have entered into a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular specifies the security measures Facebook must observe and in which Facebook agrees to fulfil data subject rights (i.e. users can, for example, address requests for access or deletion directly to Facebook). Users’ rights, particularly to access, erasure, objection and complaints to a competent supervisory authority, are not restricted by the agreements with Facebook. Further information can be found in “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection of data by, and its transmission to, Meta Platforms Ireland Limited, a company based in the EU. Further processing is the sole responsibility of Meta Platforms Ireland Limited, particularly transfers to its parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal bases: Legitimate interests (Article 6(1), first sentence, point (f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for transfers to third countries: Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).

Changes and updates

Please regularly review the content of our privacy policy. We will adapt it whenever changes in our data processing make this necessary. We will inform you if changes require an action on your part (e.g. consent) or another individual notification.

Where this privacy policy provides addresses and contact information for companies and organisations, please note that these may change over time, and check the details before making contact.

Definitions

This section provides an overview of the terminology used in this privacy policy. Where terms are defined by law, their legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Master data: Master data comprises essential information necessary to identify and manage contractual partners, user accounts, profiles and similar associations. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Master data forms the basis for any formal interaction between people and services, institutions or systems by enabling unambiguous identification and communication.
  • Content data: Content data comprises information generated when creating, editing and publishing content of any kind. This category may include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the content itself, but also includes metadata providing information about it, such as tags, descriptions, author information and publication dates
  • Contact data: Contact data is essential information enabling communication with people or organisations. It includes telephone numbers, postal and email addresses, and means of communication such as social media handles and instant messaging identifiers.
  • Metadata, communication and procedural data: Metadata, communication and procedural data are categories containing information about how data is processed, transmitted and managed. Metadata, also known as data about data, describes the context, origin and structure of other data. It may include file size, creation date, document author and revision histories. Communication data records exchanges of information between users through various channels, such as email traffic, call logs, social network messages and chat histories, including participants, timestamps and transmission paths. Procedural data describes processes and workflows within systems or organisations, including workflow documentation, transaction and activity logs, and audit logs used to trace and review operations.
  • Membership data: Membership data comprises information relating to individuals who belong to an organisation, association, online service or other group. This data is used to administer memberships, enable communication and provide services or benefits associated with membership. It may include personal identification information, contact details, membership status and duration, fee payments, participation in events and activities, and preferences and interests. It may also include data on the use of the organisation’s services. This data is collected and processed in compliance with data protection provisions, serving both administrative purposes and the promotion of member engagement and satisfaction.
  • Usage data: Usage data records how users interact with digital products, services or platforms. It includes a wide range of information showing how users use applications, which features they prefer, how long they spend on particular pages and which paths they take through an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. Usage data also plays a crucial role in identifying trends, preferences and potential problem areas in digital services
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (“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, identification number, location data, online identifier (e.g. a cookie), or one or more factors specific to that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
  • Log data: Log data is information about events or activities recorded in a system or network. It typically includes timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyse system problems, monitor security or prepare performance reports.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data, including collection, analysis, storage, transmission and deletion.
  • Contract data: Contract data is specific information relating to the formalisation of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the agreement’s specific terms and conditions. Contract data may include start and end dates, the type of agreed services or products, pricing agreements, payment terms, termination rights, renewal options and special conditions or clauses. It forms the legal basis for the relationship between the parties and is crucial for clarifying rights and obligations, enforcing claims and resolving disputes.
  • Payment data: Payment data includes all information required to process payment transactions between buyers and sellers. It is essential for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction data, verification numbers and billing information. Payment data may also include information on payment status, chargebacks, authorisations and fees.

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