for TheCircle, a brand of the adviqo UK Limited


With this data protection policy we would like to inform you of how we process personal data and to inform you about your rights. TheCircle values the protection of the personal data of its users and customers very highly. The privacy policy of TheCircle is very much in line with the provisions of the EU’s General Data Protection Regulation (GDPR) and in concert with data protection regulations ap-plicable for TheCircle Ltd and obtaining in each specific country. This privacy policy explains the type of data stored by TheCircle and how the data is used.

The privacy policy applies to the website as well as to TheCircle App.


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adviqo UK Limited

Anglia House

6 Central Avenue

St. Andrews Business Park

Thorpe St. Andrew, Norwich



United Kingdom

Tel:  +44 (0)20 7998 1120
Fax: +44 (0)20 7998 1159




Contact details of the data protection officer:





This privacy policy uses the definitions of the General Data Protection Regulation (GDPR).


“Personal data” is any information concerning an identified or identifiable natural person (hereinafter referred to as “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, men-tal, economic, cultural or social identity of that natural person.


“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisa-tion, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmis-sion, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.


“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.


“Profiling” means any form of automated processing of personal data consisting of the use of per-sonal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.


“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisa-tional measures to ensure that the personal data are not attributed to an identified or identifiable natu-ral person.


“File system” means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis;


“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 the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the con-troller or the specific criteria for his nomination may be provided for by Union or Member State law.


“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.


“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may re-ceive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The processing of this data by those public authorities shall be in compliance with the applicable data protection rules and in accordance with the purposes of the processing.


“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or proces-sor, are authorised to process personal data.


“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signi-fies agreement to the processing of personal data relating to him or her.





We gather and process the following personal data relating to you and provided to us by you:

  • Contact and address information, so long as you provided us with your contact details or if you registered on our website,
  • Online identifiers (e.g. your IP address, browser type and browser version, the operating system used, the referrer-URL, its IP address, the file name, access status, volume of data transmitted, date and time of server request),
  • Social media identifiers,
  • Meta data (Salutation, name, date of birth, address and possibly e-mail address) for legitimising a new user account,
  • Password (either entered by the user or the default password issued by the system, in any case stored in encrypted format),
  • Your customer number,
  • Payment information, as long as you provided it to us,
  • the addition “recruited by”, as long as you provided this information to us,
  • Your VAT ID number, if you are working for us and are VAT registered with HMRC.





We process your data for the following reasons:

  • for contact purposes as requested by you,
  • for information concerning our offer,
  • for processing and implementation of the contract, particularly for consultation purposes,
  • for advertising purposes,
  • for sending our newsletter by e-mail, provided you registered for this,
  • for quality assurance, and
  • for our statistics.





Your data is processed based on the following legal framework:

  • Your consent, pursuant to Article 6 (1) (a) of the GDPR,
  • For fulfilment of a contract with you, pursuant to Article 6 (1) (b) of the GDPR,
  • For fulfilment of legal obligations, pursuant to Article 6 (1) (c) of the GDPR, or
  • On the basis of our legitimate interests, pursuant to Article 6 (1) (f) of the GDPR.

If the processing of your personal data is based on our legitimate interests within the meaning of Article 6 (1) (f) of the GDPR, those interests may include

  • improvement of our web content,
  • protection of our website from misuse, and
  • to maintain our statistics.





We get the data from you (including through the devices you use). If we do not collect the personal data directly from you, we shall inform you separately of the source from which the personal data originates and, if applicable, whether it came from publicly accessible sources.





When processing your data, we work with the following service providers, which have access to your data:

  • Providers of web analysis tools,
  • Web-hosting-providers,
  • Payment service providers,
  • Transport service providers,

The use of web analysis tools may lead to data being transmitted to third countries outside the Euro-pean Union. If this happens, transmission will take place on the basis of legally envisaged contractual regulations which are meant to ensure adequate protection of your data and which you can view on request.





We shall store your personal data only for as long as it is necessary for attainment of the processing purpose, or if the storage is based on a legal retention obligation.
We store your data,

  • if you have given your consent for the processing, until you revoke your consent,
  • if we need the data for implementation of a contract, but at most for as long as the contractual relationship between you and us exists or if the retention periods are still valid,
  • if we are using the data on the basis of a legitimate interest, for as long as your interest in deletion or anonymisation does not outweigh ours.

Application data for a job as Reader shall be deleted automatically after six months, provided no con-tract has been concluded.





You have the right, partly under certain preconditions,

  • To demand information about the processing of your data, as well as to get a copy of your per-sonal data stored with us. You can, among other things, also demand information about the pur-pose of the processing, the categories of personal data being processed, the recipients of the da-ta (if the data is shared), duration of storage or the criteria for determining the storage duration;
  • To correct your data. In the event that your personal data is incomplete, you have the right to demand completion of this data, taking into consideration the purpose of the processing;
  • To have your data deleted or blocked. Reasons for demanding deletion or blocking of the data can include: the data subject revokes the consent under which the processing is being conducted; the data subject objects to the processing; the personal data is being processed unlawfully;
  • to have the processing of your data restricted;
  • to object to the processing of your data;
  • to revoke your consent for the processing of your data in future, and
  • to complain to the responsible supervisory authority about unauthorised data processing.





There is a contact form on our website which can be used for making contact electronically. If a user chooses this option, the data entered into the input mask is transmitted to us and stored here, provid-ed we do not already have this data (because you are logged on to your account). Alternatively, it is possible to make contact using the e-mail address provided. In this case, the user’s personal data that is transmitted together with the e-mail is stored.





You can voluntarily open an account on our website by providing the necessary personal data. In this process, data provided by you during registration will be transmitted to us and stored by us, subject to revocation by you. The user can temporarily or permanently close his user account at any time. To do this, the user can simply send a text message (e-mail or letter) stating clearly his intention to close the account. We expressly reserve the right to verify such requests, as well as other customer requests, with regard to their legitimacy, in order to prevent unauthorised use by third parties.





You can hold consultations with external consultants through our website, using telephone, e-mail, SMS or chat service. All information you exchange with the consultant during the conversation is vol-untary and shall remain confidential. Third parties will not listen in on your conversation.


Consultations by telephone will take place via a device connecting the external consultant and the customer. In this process, no personal data will be transmitted to the parties except the customer number. We shall record the conversations, if we are obliged to do so by law. The conversations will be deleted upon expiry of the statutory retention period.





You can rate the consultations using the evaluation function on our website, in order to give the con-sultants valuable feedback and to make it easy for other customers to select the right consultants. This is done by giving a rating of 1 to 5 stars via the telephone menu directly after the conversation, or via the website by giving a rating of 1 to 5 stars as well as a text reflecting your experience with the respective consultant.


The text evaluations together with the stars awarded will be visible on the public profile of the consult-ant and the HTML site-map, whereby the latest ratings will appear on top of the list. Users will be able to see the heading and text of the rating, the number of stars, the customer’s user name, whether it was a chat or telephone conversation, and the date and rating given.





We have taken extensive technical and organisational measures to protect your data against possible threats such as unauthorised access or unauthorised perusal, modification or distribution, as well as against loss, damage or misuse.


To protect personal data from access by unauthorised third parties during transmission, we safeguard the data transmissions using SSL-encryption, where possible. This is a standardised encryption pro-cedure for online services, particularly for the web.





Usage data is transmitted via the respective Internet browser every time you access our website, and this data is stored in log files, so-called server log files. The data records which are stored in the pro-cess contain the following data: The domain from which the user accesses the website; date and time of the request; IP address of the requesting computer, website(s) which the user visits within the con-text of the services offered; data volume transmitted; browser type and version, operating system used, name of the Internet service provider; message indicating whether the request was successful. These log file records are evaluated in an anonymous form in order to improve the service and make it more user-friendly, as well as to find and rectify errors and to control the utilised capacity of servers.





This website uses so-called cookies. A cookie is a text file with an identification number that is trans-mitted to and stored in the user’s computer during usage of the website, together with other request-ed data. This file is kept there on standby for any subsequent visit to the website and helps to authen-ticate the user. Since cookies are just simple files and not executable programmes, they don’t pose any danger to the computer. Depending on the configuration of the Internet browser selected by the user, the browser will automatically accept cookies. This configuration can, however, be changed and the storage of cookies can be deactivated or set in such a way that the user is notified as soon as a cookie is deposited on the computer. In the event that the use of cookies is deactivated, some func-tions of the website may, however, become unavailable or only partially available. You can prevent the storing of cookies on your computer by our website any time through a relevant adjustment of the settings on your Internet browser, and hence permanently object to the placement of cookies. Cook-ies that are already active on your computer can be deleted any time through the Internet browser or any other software programme. On some occasions we work together with advertising partners, who help us to make our online content more appealing to you. To this end, cookies from our partner companies (third-party cookies) will also be stored on your computer when you visit our website. If we happen to work with the aforementioned advertising partners, you will be personally and specifically informed in the next sections about the use of such cookies and the extent of the information collect-ed in each case.


We distinguish between the following types of cookies:


First-Party Cookies: First-party cookies are transmitted by the platform just visited.


Third-Party Cookies: Third-party cookies are cookies transmitted by a platform/website other than the one visited by the user. If a user accesses a website and another entity transmits a cookie through this website, this will be considered a third-party cookie.


Absolutely necessary cookies: These cookies are necessary for you to be able to navigate through the website and use its functions, e.g. to access secure sections of the website. Without these cook-ies, certain services cannot be provided, e.g. display of content tailored to your computer or device.


Performance cookies: These cookies generate information regarding the use of the website by the visitors, e.g. which web pages are requested more frequently and whether users get error messages from these web pages. However, these cookies do not gather any information relating to the identity of the visitor. All information collected by these cookies is amalgamated and is therefore anonymous. It is used only to optimise the website.


Functionality cookies: These cookies enable the website to store decisions made by you (e.g. lan-guage settings and your region), and to offer you improved and personalised functions. They can also be used to store your settings with regard to font size, fonts and other individualised parts of the web-site. They can also be used to provide services requested by you, e.g. to show a video or to use the comment function of a blog. Information collected by these cookies can be anonymised. Your surfing activities cannot be tracked on other platforms.


Social media cookies: These cookies are used when you click on a button on the website for pur-poses of sharing information on social media. The social network will record this action and can use it for marketing or advertising purposes.


Marketing / Advertising cookies: These cookies are used to show you adverts that could be rele-vant to you, based on your interests. They are also used to limit the frequency with which a particular advert is being displayed to you. We also use cookies to measure the effectiveness of our advertising campaign. They are placed there by advertising networks with our permission and they record your visit to a website. This information is then passed to other organisations, e.g. advertising providers. Oftentimes marketing and advertising cookies are attached to website functions. Our advertising cookies also enable you to participate in customer surveys and in this way allow us to get feedback from you, so that we can improve your user experience on our website.


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This website uses a cookie consent tool with technology from Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (hereinafter “Usercentrics”) to obtain valid user consent for cookies and cookie-based applications where required. he party offering this technology is Usercentrics GmbH, Rosental 4, 80331 München, Germany, website: (hereinafter referred to as “Usercentrics“).
Whenever you visit our website, the following personal data will be transferred to Usercentrics:

  • Your declaration(s) of consent or your revocation of your declaration(s) of consent
  • Your IP address
  • Information about your browser
  • Information about your device
  • The date and time you visited our website


Moreover, Usercentrics shall store a cookie in your browser to be able to allocate your declaration(s) of consent or any revocations of the former. The data that are recorded in this manner shall be stored until you ask us to eradicate them, delete the Usercentrics cookie or until the purpose for archiving the data no longer exists. This shall be without prejudice to any mandatory legal retention periods.

Usercentrics uses cookies to obtain the declarations of consent mandated by law. The legal basis for the use of such cookies is Art. 6 Sect. 1 Sentence 1 lit. c GDPR.





TheCircle uses Google Analytics, a services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This service makes it possible to analyse the use of this website and uses cookies for this. To this end, the information generated by the Cookie, such as your anonymised IP-address, is transmitted on behalf of TheCircle to a server of Google Ireland Ltd. in the USA, stored and eval-uated there. This is so because Google Analytics was given the extension code “gat._anonymizeIp();” on this website. This ensures anonymised collection of IP-addresses. Anonymisation of your IP-address is generally done through the truncating of the IP-address by Google Ireland Ltd. within the Europe-an Union or in other member states of the European Economic Area (EEA). In the context of the Google Analytics-advertising function, remarketing and the reports are used to provide services ac-cording to demographic features and interests. These procedures help align advertising measures more closely with the interests of the respective users, with the help of the information about user behaviour. In the context of remarketing, personalised advertising measures can be displayed on other websites based on your surfing behaviour on the website of TheCircle. In this process, advertis-ing materials can contain products which you have looked at before on the website of TheCircle. Pro-vided you have agreed that your web and App browser history be connected to your Google account and that your Google account be used to personalise advertisements, Google will use this data for remarketing purposes across multiple devices. You can revoke the collection of your data by Google Analytics any time. For this, you have the following possibilities at your disposal:


Most browsers accept cookies automatically. You can prevent the use of cookies by adjusting the relevant settings of the browser software; in this case, however, it may then not be possible to use all functions of the website. The adjustments have to be made separately for each browser used. Furthermore, you can prevent the collection and processing of this data by Google Ireland Ltd. by downloading and installing the browser add-on available through the following link: As an alternative, or within browsers on mobile devices, this can be done by clicking on the following link: Deactivating Google Analytics An Opt-Out-Cookie will be stored in the user’s device for the website of TheCircle and be in effect for the browser currently being used. If cookies are deleted in this browser, this link must be clicked again. You can find detailed information about the terms of use and data protection at or under





This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. Google Tool Manager only implements tags. This means that no cookies are used and no personal information is collected. Google Tool Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, it remains valid for all tracking tags if they are implemented with the Google Tag Manager.





To continuously improve our offer, we use the service „unbounce“ of the Canadian company unbounce Marketing Solutions Inc., 400-401 West Georgia Street, Vancouver, BC, Canada, V6B 5A1. For advertising campaigns, individual pages ("landing pages") might be hosted by unbounce. The user's browser communicates directly with unbounce so that the IP address is transmitted and cookies can be set. All information entered by the user on these pages is also stored anonymously by unbounce. We receive a statistical evaluation of the activities of the users on our platforms. The information sent to us is anonymous, so that we cannot establish a personal reference.

Further information on unbounce and data protection at unbounce can be found at:





This website uses the Facebook Pixel and the "Custom Audiences" function of Facebook Ireland Lim-ited, 4 Grand Canal Square, Dublin 2, Ireland (hereinafter referred to as: “Facebook”). This function serves the purpose of presenting visitors to this website with advertisements ("Facebook-Ads") based on their interests, within the framework of their visit to the social network provider Facebook. Further-more, the function also makes it possible to display individualised advertising banners in the social network provider Facebook, which can contain products previously viewed by the user on the website of TheCircle (remarketing).


For this, the Facebook Pixel was implemented by Facebook on this website. It is through this Pixel that a direct connection to the Facebook servers will be established during your visit to the website. In this process, information will be sent to the Facebook servers to the effect that you have, among oth-er things, visited this website (including information about the type of products you bought and in which quantities), and Facebook will assign this information to your personal Facebook account, if you are a Facebook customer. If you then visit our web pages, a direct connection will be established via the tracking pixel between your browser and the Facebook server. In this way, Facebook will receive information, among others from your browser, that your terminal (e.g. your PC) has accessed our web page. If you are a Facebook user, Facebook can use this information to associate your visit to our web pages with your Facebook account. In the same way, Facebook can in the end recognise whether a Facebook advert was effective – for instance, whether it led to the conclusion of an online purchase. In this regard, we and, if necessary, our cooperation partners, receive only statistical data from Facebook without any reference to a concrete person. This is done to assess the effectiveness of adverts. Tracking using the Pixel is done in a way which does not enable us to identify you as a person, and it marks users as visitors to our website only in a way that is anonymous for us. Face-book uses cookies for this process. Facebook stores and uses the data collected with the help of the Pixel. This happens at least partially also outside the territorial area of applicability of the EU data protection regulations. You can find detailed information about the collection and use of data by Face-book, as well as the rights and possibilities open to you in this regard for the protection of your priva-cy, in Facebook’s data protection guidelines available at Alternatively, you can deactivate the “Custom Audiences” remarketing function at To do this, you must be logged on to Facebook.


Pinterest Conversion Tracking:

Our website uses Pinterest social network conversion tracking technology (Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland), which enables us to show Pinterest relevant advertisements and offers on Pinterest to our website visitors who have already taken an interest in our website and our content/offers and are Pinterest members. For this purpose, a so-called conversion tracking pixel from Pinterest is integrated into our pages, which tells Pinterest when you visit our website that you have visited our website and which parts of our offers you are interested in. For example, if you have taken an interest in our subscriptions on our website, Pinterest may display an advertisement on our subscriptions.

You can opt-out of the collection of data to display interest-based advertising on Pinterest at any time in your Pinterest account settings at or at





TheCircle Ltd GmbH uses the Conversion-Tracking system of Google Ireland Limited (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), being the latter’s advertising customer (“Google Adwords customer”), for purposes of marketing performance measurement. For this pur-pose, a Google Adwords pixel is integrated on each of the registration pages of TheCircle, and this pixel transmits the registration event to Google without any details of the customer concerned – be-sides the common technical features of every website visit (e.g. browser, IP-address). For purposes of recognition and assignment of the users, a cookie will be installed by Google, provided you ac-cessed the website through a Google advert. These cookies will lose their validity after 30 days. Each AdWords user receives a different Cookie. Cookies cannot therefore be tracked via the websites of AdWords users. For further information on data protection at Google, visit Besides, users can also deactivate or revoke Google adverts as a whole or in parts at (execute Opt-Out).





Using the re-marketing technology from Google Ireland Limited (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland), users who have already visited websites belonging to The-Circle Ltd will once again be targeted through interest-based advertising on the web pages of the Google’s partner network. In this process, advertising materials can contain products previously viewed by the user on the website of TheCircle (remarketing). To this end, Google remarketing track-ing pixels are integrated on this web page, and these collect and transmit information about user be-haviour on the website (e.g. advisors viewed), the technical features of the visit to the website (e.g. the browser used, IP-address) as well as the purchase behaviour (e.g. last-visited advisors) without reference to any person. Google uses cookies for purposes of recognition and assignment of users. Provided users have agreed that their web and App browser history can be connected to their Google account and that information from their Google account can be used by TheCircle to personalise ad-vertisements that they see on the web, Google will use the data of these registered users together with Google Analytics data to create and define target group lists for remarketing purposes across multiple devices. To support this function, Google Analytics will collect Google-authenticated IDs of these users. This personal data from Google will temporarily be merged with Google Analytics data from TheCircle to form target groups.


You can find more information and possibilities concerning the deactivation of this ad placement at (go to “Ad settings” link, then “Deactivation”).





In addition, our websites use Conversion Tracking and the Universal Event Tracking from Mi-crosoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). For this purpose, tracking pixels from Microsoft are integrated on the order confirmation page and on other selected pages of this web shop. When the user visits these web pages, the usual technical infor-mation (such as the operating system, browser used, IP-address) as well as information about the user’s surfing behaviour (e.g. products viewed), is transmitted to Microsoft and stored there. If an order is made, only data without any references to the person, such as the order number, item num-ber and the order value, is transmitted to Microsoft. This information helps evaluate and optimise TheCircle’s advertisements in connection with Microsoft Bing ads programme.


For purposes of recognition and assignment of the users, so-called cookies are used, provided you accessed our website through a Microsoft Bing advert. We together with Microsoft Bing can know that someone clicked on an advert and was forwarded to our website. No personal information regarding the identity of the user is disclosed. If you do not wish to take part in the tracking process, you can also reject the placement of a Cookie required for this, through the browser settings, which generally deactivates the automatic installation of cookies. You can find more information about data protection and the installed cookies, as well as the possibility of revocation at Microsoft Bing, on Microsoft’s website:





Emarsys eMarketing Systems AG (Stralauer Platz 34, 10243 Berlin, Germany; is also used in the technical processing of newsletter mailings and is an Austrian enterprise with head-quarters in Berlin, which provides the software and infrastructure for sending consent-based electronic messages. Emarsys is aware of its obligation towards recipients of such messages and has a zero-tolerance policy for spam.


Furthermore, Emarsys offers various possibilities of analysing how the despatched newsletters are opened and used, e.g. to how many users an e-mail was sent, whether the e-mails were rejected, and whether the users unsubscribed after receiving the e-mail. These analyses are, however, only group-related and we do not use them to rate individuals.


If you don’t wish to continue receiving our newsletter, you can unsubscribe at any time by clicking on the relevant link contained in every mailing.


For further information on data protection at Emarsys, visit





We use Hotjar, an essentially tracking-code-based web analysis tool of Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta. Hotjar helps us to record in an anonymised manner interactions of randomly selected individual visitors to our website. In this way, a record of mouse movements, for example, and clicks is created with the aim of finding ways to im-prove our web content. In addition, Hotjar helps us to evaluate information regarding the operating system, browser, incoming and outgoing referrals (links), geographical origin as well as resolution and the type of terminal accessing our website, for statistical purposes. At the same time, we use Hotjar to allow anonymous user feedback using the so-called “Feedback Pools”. The information collected is not personal; it is stored by Hotjar Ltd. and not shared with third parties. If you do not wish to have website analysis done using Hotjar, you can deactivate this function on all websites which use Hotjar by inserting a DoNotTrack-Header in your browser (opt-out): You can get supplementary information on the functions and data use in connection with Hotjar at:





Our website uses Pingdom, a service of the Pingdom AB Company, Kopparbergsvägen 8, 72213 Västeras, Sweden. Pingdom uses, among other things, cookies which are stored on your computer and enable us to analyse how our website is used. In connection with this usage, data such as the IP-address in particular and other data tracking the activities of users is transmitted to a Pingdom AB server and stored there. You can prevent the collection and sharing of your personal data (particularly your IP-address), as well as the processing of this data, by deactivating the running of Java-Script in your browser or by installing a tool like “NoScript”. You can access further information on data protec-tion in connection with the use of Pingdom under the following link:





This website uses SnapEngage, a Live-Chat-service of SnapEngage, LLC (hereinafter referred to as: “Snapengage”). SnapEngage uses so-called cookies; these are text files which are stored on your computer and enable an analysis of your use of our website. The information generated (including your truncated IP-address), is sent to a server of SnapEngage in the USA and stored there, in order to evaluate your use of the Chats and to provide us with reports (e.g. about the average length of a Chat). SnapEngage will transmit this information to third parties if necessary, provided that this is legally stipulated or as long as third parties shall process this data on behalf of SnapEngage. SnapEn-gage will on no account merge your truncated IP-address with other data from SnapEngage. You can prevent the installation of the cookies by changing the settings in your browser software. We would like to point out, however, that in this case you may be unable to use all of the functions of our web-site fully. By using this website you otherwise agree to the processing of the data collected about you by SnapEngage in the way described above and for the purpose mentioned above. You can get more information via the following link:





We use the services of Adjust, an App analysis service, for analysing the App usage (adjust GmbH, Saarbrücker Str. 38a, 10405 Berlin, Germany). The Adjust service has been tested and certified ac-cording to ePrivacyseal (European Seal for your Privacy) – see Adjust uses the IP and Mac-addresses of the UserApp-users, but these are used exclusively in an anonymised form. It is therefore not possible to trace this data back to a natural person. The information collected through the use of Adjust is used merely to analyse the function and use of the App by creating anonymous evaluations and graphics of the number of visits, number of web pages accessed per user, etc. The analyses are used exclusively for personal market research as well as for the optimisation and a needs-oriented design of the App.


Possibility of revocation: You can stop any tracking associated with the App in future by selecting the “Data protection” item on the menu and adjusting the sliding switch accordingly (“Turn off Tracking”).





This website further uses the Visual Website Optimiser, a web analysis service of Wingify, Inc. (here-inafter referred to as: “VWO”). This is a web analysis service of Wingify, 14th Floor, KLJ Tower North, Netaji Subhash Place, Pitam Pura, Delhi 110034, India. VWO tests the user-friendliness of certain web pages. In this process, measurements relating to user behaviour are anonymously collected. We have no possibility of assigning these anonymous measurements to your person – say through the assignment of your IP-address or in other ways. To get meaningful test results, so-called cookies are also used, i.e. the programme uses the function designated by your browser to temporari-ly store information in the interim and retrieve it later. As long as the cookies do not already get delet-ed at the end of the session, they will be available for a maximum of 100 days (you can get more details here: You can delete the cookies in your browser at any time.


Furthermore you may withdraw from participation in the tests altogether through the following link:


You can find further information on data protection here:





We use Plugins of the service provider AddThis on our website. AddThis is operated by AddThis, LLC, 1595 Spring Hill Rd, Suite 300, Vienna, VA 22182, USA (hereinafter referred to as: “AddThis”). Add-This provides tools for constructing and designing websites ( This is meant to make it easier for visitors to the website to share the respective current page with other Internet users by e-mail or in social networks. You can recognise these Plugins by the buttons labelled "Tweet", “E-mail", “LinkedIn", and "g +1”, which are integrated into sections of our website. In addition, AddThis provides tools for website operators to help them analyse and improve the use of their own website or to ena-ble them to address the user directly. In this process, AddThis also uses cookies and web beacons (little graphics, “number pixels”, which make it possible to record and to analyse a log file). If you use an AddThis-Plugin, your Internet browser will set up a direct connection with the servers of AddThis and, if necessary, the selected social network. The data generated in the process (e.g. time of use or browser language) are transmitted to AddThis and processed there. If you send contents of our web-site to social networks, a connection can be established between the visit of the website and your user profile at the respective social network. You can find detailed information about data processing and data protection by AddThis at:


We do not process the data in question, nor do we share it with third parties. By using the AddThis Plugin, you agree to the processing of your data by AddThis.





We use the service provider YouTube for the integration of videos, among other things, in our web-site. YouTube is operated by YouTube LLC with headquarters in 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Ireland Limited with headquarters in Gordon House, Barrow Street, Dublin 4, Ireland.


If you visit pages of our website equipped with a Plugin – for example, our media library – a connec-tion is established with the YouTube servers, and the Plugin is displayed in the process. Through this, a message will be sent to the YouTube server indicating which of our websites you visited. If you are logged onto YouTube as a member, YouTube will assign this information to your personal user ac-count. If the Plugin is used, e.g. when the start button of a video is clicked, this information will also be assigned to your user account. You can prevent this assignment by logging out of your YouTube user account as well as other user accounts belonging to YouTube LLC and Google Ireland Ltd. and deleting the relevant cookies of those providers before using our website.


You can find further information on data processing and data protection by YouTube (Google) at





Java-Script code from GeoTrust, Inc., 350 Ellis Street, Mountain View, CA 94043-2202, USA (herein-after referred to as: “GeoTrust”) is reloaded on our website. If you have activated Java script in your browser and you have not installed any Java script blocker, your browser will probably transmit per-sonal data to GeoTrust. To prevent the running of Java-Script code from GeoTrust completely, you can install a Java script blocker (e.g. or You can find more information about this in the privacy policy of GeoTrust at:





With your consent, we use the “visitor action pixel” from Facebook Inc. within our websites. With the help of these pixels, we can track the actions of users after they have seen or clicked on an advert. This will enable us to gauge the effectiveness of adverts on the mentioned platforms for market re-search purposes. The data collected in this way is anonymous to us; that is, we do not see the per-sonal data of individual users. This data is, however, stored and processed by the respective platform providers – something we shall inform you of to the best of our knowledge. For more information, we refer you to the respective privacy policies:





Plugins of the social network provider, Facebook, are integrated on our website. The provider is Face-book Inc., 1 Hacker Way, Menlo Park, California 94025, USA. You can recognise the Facebook Plugins by the Facebook logo or the “Like” button on our web page. You can find an overview of the Facebook Plugins here:


If you go to our web pages, a direct connection will be established between your browser and the Facebook server via the Plugin. Facebook will then receive the information that you have visited our website with your IP-address. If you click on the Facebook "Like” button while you are logged onto your Facebook account, you can interlink the contents of our web pages onto your Facebook profile. Facebook can then use this information to assign your visit to our websites to your Facebook account. We would like to point out that we as the providers of the web pages do not have any knowledge of the contents of the transmitted data, nor do we receive any information of how it is used by Facebook. You can find more information about this in the privacy policy of Facebook at:





You can also register with your respective Social Network Login (Facebook Inc.) on our website by disclosing the data stored in your respective Social Network profile. Your registration will then be done automatically using your profile information at Facebook. This includes, among other things, your name and e-mail address. The use of this function is subject to the data protection conditions and terms of use of the respective Social Network provider. You can find more information about this in the privacy policy of Facebook at:





This website uses Dynatrace User Experience Management (UEM), a service of Dynatrace LLC. The information generated by the Cookie about your use of this website is locally stored in our company. Dynatrace will on no account reprocess the collected personal data; the use of the data is incumbent upon the operator of this website. You can prevent the storage of your data through the relevant set-tings of your browser software. We would like to point out, however, that in this case you may not be able to use all of the functions of this website fully. You can find further information at





We use Google Fonts, a service of Google Ireland Ltd. (hereinafter referred to as: “Google”). The integration of these web fonts is done by accessing a server, usually a server of Google Ireland Ltd. in the USA. Through this, a message will be sent to the server indicating which of our websites you visited. The IP-address of the browser of the user whose terminal accessed this website is also stored by Google. You can find more information in Google’s privacy policy, which you can access through:





Furthermore, we use the services of the Applift enterprise, Rosenstraße 17, 10178 Berlin, Germany, for our Apps. This service provider also uses merely pseudonymous data to improve our web content. If you would like to revoke the data processing consent, you can do it through





To send push-messages in Android and iOS Apps we use the Braze service, a programme made by Braze Inc. NYC, 318 West 39th Street, 5th Floor, New York, NY 10018, USA. Braze stores data un-der an anonymised ID concerning the use of the App, but it does not store any personal data. For more information regarding compliance with data protection by Braze, please visit:





For our Smartphone-App we use the Crashlytics tool; this is part of the Fabric platform run by Twitter for purposes of recording crashes by the App. No personal data is transmitted by this tool. Only real-time crash reports are sent with exact information about the code positions involved and device infor-mation, which should make it easy to carry out maintenance and to improve the resultant stability of the App. You can view the privacy policy of Crashlytics here:





We use the “Firebase” tool in our App. This is a real-time database which we use for real-time data exchange and storage in our App, with the aim of improving and further developing the App. In the process, user data is transmitted in an anonymised form to Firebase. Firebase is a subsidiary of Google and has its headquarters in San Francisco (CA), USA.


You can find the privacy policy of Firebase at: as well as the privacy policy of Google at:





We also use the Mixpanel analysis service, which is a service of Mixpanel Inc., USA (“Mixpanel”), to carry out statistical evaluations that enable us to optimise and to design our website functions in a more appealing way. Mixpanel uses cookies to gather information about the type of your browser, your operating system, your language settings, the search keywords entered by you and your IP ad-dress. This data is then transmitted to a server of Mixpanel in the USA. We receive your IP address from Mixpanel exclusively in an anonymised form.


You can object to the collection and storage of your data by Mixpanel any time through the following link: Furthermore, you can object to the collection of data for these pur-poses by deactivating cookies in your browser or device settings (cf. section XVI. Cookies) in this regard.


You can find more detailed information about Mixpanel and the data guidelines of Mixpanel here





As long as you download our App, the necessary information is transmitted to the respective App store. These include in particular user name, e-mail address, time of download and the individual de-vice code. However, we do not have any influence on this data collection, since this is initiated from the respective App Store operator. We process the data provided to us for as long as this is neces-sary for downloading the App onto your mobile device (e.g. Smartphone or tablet). This data is not stored with us. In this connection, please also pay attention to the data protection information of the App store operator:





Payments are processed through our partner Adyen BV, Simon Carmiggelstraat 6 – 50, 1011 DJ Am-sterdam, Netherlands (hereinafter referred to as: “Adyen”). We shall transmit your IP address to Adyen for purposes of preventing and exposing fraud cases. Your IP address will then be stored by Adyen during the process of storing the credit card as well as during the online prepayment proce-dure. All data is stored in encrypted form.





The PayPal service is provided by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg, Luxembourg. When paying by PayPal, you will be directed via a link to the website of PayPal. To use this service, PayPal collects, stores and processes your personal data, such as your name, address, telephone number and your e-mail address, as well as your credit card or bank account details. PayPal is solely responsible for the protection and handling of data collected by Pay-Pal. In this respect, the PayPal terms of use shall apply; these are available at For further information on how your data is handled by PayPal, you can access their privacy policy availa-ble at:



Updated: 17/03/2020





Privacy Policy for our Facebook and Instagram Pages


When you visit our Facebook Fanpage or Instagram Page (hereinafter "Facebook"), we are jointly responsible with Facebook for the processing of your personal data. Instagram is part of the Facebook group of companies and shares infrastructure, systems and technology with Facebook and other Facebook companies (


Below we inform you about the associated data processing:


Information about the collection of personal data and contact details of the person responsible



  Data Purpose of Use Legal Basis
1 User interactions (postings, likes etc.) User communication via social media Art. 6 para. 1 lit. f) GDPR
2 Cookies Target group advertising Art. 6 para. 1 lit. f) GDPR
3 Demographic data (e.g. based on age, location, language or gender) Target group advertising Art. 6 para. 1 lit. f) GDPR
4 Aggregated data without personal reference (e.g. page activities, page views, page previews, likes, recommendations, articles, videos, page subscriptions including origin, times of day) Target group advertising Art. 6 para. 1 lit. f) GDPR



The promotional use of your personal data is particularly important for Facebook. We use the statistics function to learn more about the visitors of our fan page. Using this function enables us to adapt our content to the respective target group, by using demographic information about the users, such as age and locations.


To provide the social media service in the form of our Facebook fan page and to use the Insight function, Facebook usually stores cookies on the user's device. These include session cookies that are deleted when the browser is closed and persistent cookies that remain on the device until they expire or are deleted by the user.


A cookie is a tiny text file that allows a website to recognize a browser. When a website is called up, cookies are stored in a text file on the computer and are called up and read the next time the web server is called up. As a user, you can decide yourself via your browser settings whether and which cookies you wish to allow, block or delete.


According to Facebook, the cookies used by Facebook are used for authentication, security, website and product integrity, advertising and measurements, website functions and services, performance, and analysis and research. Details of the cookies used by Facebook (e.g., cookie names, duration of function, content collected and purpose) can be found at on the following links: and There you will also find the option to deactivate the cookies used by Facebook. The collection and storage of data through the use of the above-mentioned Facebook cookies can also be refused at any time with effect for the future by clicking on the following opt-out link:



Note about Facebook Insights:

For statistical evaluation purposes we use the Facebook Insights function. In this context, we receive anonymous data on the users of our Facebook fan page. A conclusion to your person is not possible for us. For further information, please refer to Facebook's cookie policy.



Pursued legitimate interests, provided that the legal basis is Art. 6 para. 1 lit. f) GDPR

We see our legitimate interest in data processing in the presentation of our company and our products and services for your information.



Transmission and use of personal data

Recipients or categories of recipients: Facebook and InstagramIf you interact within Facebook and Instagram directly, Facebook Inc, 1601 Willow Road, Menlo Park, California 94025, USA, also has access to your data. Facebook is located here in a third country where the level of data protection is lower. Facebook is subject to the EU-U.S. Privacy-Shield in order to guarantee an adequate level of data protection according to European standards.




We cannot fulfil our information obligations according to Art. 13 EU-DSGVO, as only Facebook has full access to the user data. If you wish to exercise your rights as a data subject, please contact Facebook directly here. You are entitled to the following rights:

  • Right of access by the data subject: Art. 15 EU-GDPR
  • Right to rectification: Art. 16 EU-GDPR
  • Right to erasure (‘right to be forgotten’): Art. 17 EU-GDPR
  • Right of restriction of processing: Art. 18 EU-GDPR
  • Right to object: Art. 21 EU-GDPR
  • Right to data portability: Art. 20 EU-GDPR
  • Right to lodge a complaint with a supervisory authority: Art. 77 EU-GDPR
  • Right of withdrawal consent at any time: Art. 7 Para. 3 EU-GDPR


According to Art. 21 EU-GDPR,you have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. 2 The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.if personal data are processed for the purpose of direct marketing, you also have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is necessary to ensure that the data are not processed for the purpose of direct marketing.



Data protection officer

You can contact the data protection officer of Facebook via the online contact form provided by Facebook at




Updated: 23.06.2020





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