Privacy Policy


With the following privacy policy, we would like to inform you which types of your personal

data (hereinafter also abbreviated as “data”) we process for which purposes and in which

scope. The privacy statement applies to all processing of personal data carried out by us, both

in the context of providing our services and on our websites, in mobile applications and

within external online presences, such as our social media profiles (hereinafter collectively

referred to as “online services”).

The terms used are not gender specific.

Last Update: 15. August 2021

Table of contents

  • Preamble
  • Controller
  • Overview of processing operations
  • Legal Bases for the Processing
  • Security Precautions
  • Transmission of Personal Data
  • Data Processing in Third Countries
  • Erasure of data
  • Use of Cookies
  • Provision of online services and web hosting
  • Contact and Enquiry Management
  • Changes and Updates to the Privacy Policy
  • Rights of Data Subjects
  • Terminology and Definitions


Silke Maria Haas C / Jaume III 2007320 Santa Maria Mallorca, Spain

E-mail address

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are

processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data (e.g., names, addresses).
  • Content data (e.g., text input, photographs, videos).
  • Contact data (e.g., e-mail, telephone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g., websites visited, interest in content, access times).

Categories of Data Subjects

  • Communication partner (Recipients of e-mails, letters, etc.).
  • Users (e.g., website visitors, users of online services).

Purposes of Processing

  • Provision of our online services and usability.
  • Direct marketing (e.g., by e-mail or postal).
  • Contact requests and communication.

Legal Bases for the Processing

In the following, you will find an overview of the legal basis of the GDPR on which we base

the processing of personal data. Please note that in addition to the provisions of the GDPR,

national data protection provisions of your or our country of residence or domicile may

apply. If, in addition, more specific legal bases are applicable in individual cases, we will

inform you of these in the data protection declaration.

  • Consent (Article 6 (1) (a) GDPR)– The data subject has given consent to the

processing of his or her personal data for one or more specific purposes.

  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR)

Performance of a contract to which the data subject is party or to take steps at the

request of the data subject prior to entering a contract.

  • Legitimate Interests (Article 6 (1) (f) GDPR)– Processing is necessary for the

purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and

freedoms of the data subject which require protection of personal data.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal

requirements, considering the state of the art, the costs of implementation and the nature,

scope, context, and purposes of processing as well as the risk of varying likelihood and

severity for the rights and freedoms of natural persons, to ensure a level of security

appropriate to the risk.

The measures include safeguarding the confidentiality, integrity, and availability of data by

controlling physical and electronic access to the data as well as access to, input, transmission,

securing and separation of the data. In addition, we have established procedures to ensure that

data subjects’ rights are respected, that data is erased, and that we are prepared to respond to

data threats rapidly. Furthermore, we take the protection of personal data into account as

early as the development or selection of hardware, software, and service providers, in

accordance with the principle of privacy by design and privacy by default.

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to

other places, companies, or persons or that it is disclosed to them. Recipients of this data may

include, for example, service providers commissioned with IT tasks or providers of services

and content that are embedded in a website. In such a case, the legal requirements will be

respected and corresponding contracts or agreements, which serve the protection of your data,

will be concluded with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European

Economic Area (EEA)) or the processing takes place in the context of the use of third-party

services or disclosure or transfer of data to other persons, bodies, or companies, this will only

take place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we process or have

processed the data only in third countries with a recognised level of data protection, on the

basis of special guarantees, such as a contractual obligation through so-called standard

protection clauses of the EU Commission or if certifications or binding internal data

protection regulations justify the processing (Article 44 to 49 GDPR, information page of the

EU Commission:


Erasure of dataThe data processed by us will be erased in accordance with the statutory provisions as soon as

their processing is revoked, or other permissions no longer apply (e.g., if the purpose of

processing this data no longer applies or they are not required for the purpose).

If the data is not deleted because they are required for other and legally permissible purposes,

their processing is limited to these purposes. This means that the data will be restricted and

not processed for other purposes. This applies, for example, to data that must be stored for

commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal

claims or to protect the rights of another natural or legal person.

In the context of our information on data processing, we may provide users with further

information on the deletion and retention of data that is specific to the respective processing


Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a

browser on the user’s computer. A cookie is primarily used to store information about a user

during or after his visit within an online service. The information stored can include, for

example, the language settings on a website, the login status, a shopping basket, or the

location where a video was viewed. The term “cookies” also includes other technologies that

fulfil the same functions as cookies (e.g., if user information is stored using pseudonymous

online identifiers, also referred to as “user IDs”).

The following types and functions of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the

latest after a user has left an online service and closed his browser.

  • Permanent cookies: Permanent cookies remain stored even after closing the browser.

For example, the login status can be saved or preferred content can be displayed

directly when the user visits a website again. The interests of users who are used for

range measurement or marketing purposes can also be stored in such a cookie.

  • First-Party-Cookies: First Party-Cookies are set by us.
  • Third party cookies: Third party cookies are mainly used by advertisers (so-called

third parties) to process user information.

  • Necessary (also: essential) cookies: Cookies can be necessary for the operation of a

website (e.g., to save logins or other user inputs or for security reasons).

  • Statistics, marketing, and personalisation cookies: Cookies are also generally used

to measure a website’s reach and when a user’s interests or behaviour (e.g., viewing

certain content, using functions, etc.) are stored on individual websites in a user

profile. Such profiles are used, for example, to display content to users that

corresponds to their potential interests. This procedure is also referred to as

“tracking”, i.e., tracking the potential interests of users. If we use cookies or

“tracking” technologies, we will inform you separately in our privacy policy or in the

context of obtaining consent.Information on legal basis: The legal basis on which we process your personal data with the

help of cookies depends on whether we ask you for your consent. If this applies and you

consent to the use of cookies, the legal basis for processing your data is your declared

consent. Otherwise, the data processed with the help of cookies will be processed on the basis

of our legitimate interests (e.g., in a business operation of our online service and its

improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

Retention period: Unless we provide you with explicit information on the retention period

of permanent cookies (e.g., within the scope of a so-called cookie opt-in), please assume that

the retention period can be as long as two years.

General information on Withdrawal of consent and objection (Opt-Out): Respective of

whether processing is based on consent or legal permission, you have the option at any time

to object to the processing of your data using cookie technologies or to revoke consent

(collectively referred to as “opt-out”). You can initially explain your objection using the

settings of your browser, e.g., by deactivating the use of cookies (which may also restrict the

functionality of our online services). An objection to the use of cookies for online marketing

purposes can be raised for a large number of services, especially in the case of tracking, via

the websites and In

addition, you can receive further information on objections in the context of the information

on the used service providers and cookies.

Processing Cookie Data Based on Consent: We use a cookie management solution in

which users’ consent to the use of cookies, or the procedures and providers mentioned in the

cookie management solution, can be obtained, managed, and revoked by the users. The

declaration of consent is stored so that it does not have to be retrieved again and the consent

can be proven in accordance with the legal obligation. Storage can take place server-sided

and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) to be

able to assign the consent to a user or and/or his/her device. Subject to individual details of

the providers of cookie management services, the following information applies: The

duration of the storage of the consent can be up to two years. In this case, a pseudonymous

user identifier is formed and stored with the date/time of consent, information on the scope of

the consent (e.g., which categories of cookies and/or service providers) as well as the

browser, system and used end device.

  • Processed data types: Usage data (e.g., websites visited, interest in content, access

times), Meta/communication data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f)


Provision of online services and web hosting

To provide our online services securely and efficiently, we use the services of one or more

web hosting providers from whose servers (or servers they manage) the online services can

be accessed. For these purposes, we may use infrastructure and platform services, computing

capacity, storage space and database services, as well as security and technical maintenance


The data processed within the framework of the provision of the hosting services may include

all information relating to the users of our online services that is collected during use and

communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online services to browsers, and all entries made within our online

services or from websites.

Collection of Access Data and Log Files: We, ourselves, or our web hosting provider,

collect data based on each access to the server (so-called server log files). Server log files

may include the address and name of the web pages and files accessed, the date and time of

access, data volumes transferred, notification of successful access, browser type and version,

the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP

addresses and the requesting provider.

The server log files can be used for security purposes, e.g., to avoid overloading the servers

(especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability

and optimal load balancing of the servers.

  • Processed data types: Content data (e.g., text input, photographs, videos), Usage

data (e.g., websites visited, interest in content, access times), Meta/communication

data (e.g., device information, IP addresses).

  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Contact and Enquiry Management

When contacting us (e.g., by contact form, e-mail, telephone or via social media), the data of

the inquiring persons are processed insofar as this is necessary to answer the contact enquiries

and any requested activities.

The response to contact enquiries within the framework of contractual or pre-contractual

relationships is made to fulfil our contractual obligations or to respond to (pre)contractual

enquiries and otherwise based on the legitimate interests in responding to the enquiries.

  • Processed data types: Inventory data (e.g., names, addresses), Contact data (e.g.,

e-mail, telephone numbers), Content data (e.g., text input, photographs, videos).

  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Contact requests and communication.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR),

Legitimate Interests (Article 6 (1) (f) GDPR).

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection

declaration. We will adjust the privacy policy as changes in our data processing practices

make this necessary. We will inform you as soon as the changes require your cooperation

(e.g., consent) or other individual notification.If we provide addresses and contact information of companies and organizations in this

privacy policy, we ask you to note that addresses may change over time and to verify the

information before contacting us.

Rights of Data Subjects

As data subject, you are entitled to various rights under the GDPR, which arise from Articles

15 to 21 of the GDPR:

  • Right to Object: You have the right, on grounds arising from your situation to

object at any time to the processing of your personal data which is based on

letter (e) or (f) of Article 6(1) GDPR, including profiling based on those

provisions. Where personal data are processed for direct marketing purposes,

you have the right to object at any time to the processing of the personal data

concerning you for the purpose of such marketing, which includes profiling to

the extent that it is related to such direct marketing.

  • Right of withdrawal for consents: You have the right to revoke consents at any


  • Right of access: You have the right to request confirmation as to whether the data in

question will be processed and to be informed of this data and to receive further

information and a copy of the data in accordance with the provisions of the law.

  • Right to rectification: You have the right, in accordance with the law, to request the

completion of the data concerning you or the rectification of the incorrect data

concerning you.

  • Right to Erasure and Right to Restriction of Processing: In accordance with the

statutory provisions, you have the right to demand that the relevant data be erased

immediately or, alternatively, to demand that the processing of the data be restricted

in accordance with the statutory provisions.

  • Right to data portability: You have the right to receive data concerning you which

you have provided to us in a structured, common and machine-readable format in

accordance with the legal requirements, or to request its transmission to another


  • Complaint to the supervisory authority: In accordance with the law and without

prejudice to any other administrative or judicial remedy, you also have the right to

lodge a complaint with a data protection supervisory authority, in particular a

supervisory authority in the Member State where you habitually reside, the

supervisory authority of your place of work or the place of the alleged infringement, if

you consider that the processing of personal data concerning you infringes the GDPR.Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms

are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are

binding. The following explanations, on the other hand, are intended above all for the

purpose of comprehension. The terms are sorted alphabetically.

  • 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 the processing of personal data.

  • 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, an identification number, location data, an online identifier or to one or

more factors specific to the physical, physiological, genetic, mental, economic,

cultural or social identity of that natural person.

  • Processing: The term “processing” covers a wide range and practically every

handling of data, be it collection, evaluation, storage, transmission or erasure.