Privacy Policy

This Privacy Policy informs users about the nature, scope, and purposes of the collection and use of personal data by the data controller, House of Spa.

1. WHAT IS THIS PRIVACY POLICY ABOUT?

House of Spa (hereinafter also referred to as “we” or “us”) collects and processes personal data relating to you or other individuals (so-called “third parties”). We use the term “data” here interchangeably with “personal data” or “personally identifiable information.” In this Privacy Policy, we describe what we do with your data when you use our website, purchase or use our services or products, enter into or fulfill contracts with us, communicate with us, or otherwise interact with us, or if you are a shareholder of our company. In addition, we may provide you with separate information regarding the processing of your data (e.g., in forms, contract terms, or additional privacy policies). If you provide us with data about other individuals (e.g., family members, coworkers), we assume that you are authorized to do so and that this data is accurate. By submitting data about third parties, you confirm this. Please also ensure that these third parties have been informed of this Privacy Policy. This Privacy Policy is based on the Swiss Data Protection Act (“DSG”), the revised Swiss Data Protection Act (“revDSG”), and the requirements of the EU General Data Protection Regulation (“GDPR”). However, whether and to what extent these laws apply depends on the individual case.

2. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA?

House of Spa is responsible under data protection law for the data processing described in this Privacy Policy, unless otherwise specified in individual cases. Our address is: House of Spa, HoS Beckenried GmbH, Obere Allmend 9, CH-6375 Beckenried

3. WHAT DATA DO WE PROCESS?

We process various categories of your personal data. The most important categories are as follows:

• Master Data: This includes basic information (e.g., name, contact information), additional information about you (e.g., regarding roles and functions), as well as your relationship with us (e.g., visitor, other customer, supplier, service provider, or employee of such a party, etc.), bank account information, date of birth, photos, copies of identification documents, customer history, any powers of attorney, signature authorizations, and declarations of consent, as well as information about third parties (e.g., contact persons, representatives). This may also include health-related data, such as food intolerances.
• Registration Data: This includes data collected when you register with us or that you provide to us (e.g., name, email address), as well as data collected in connection with contests or when redeeming gift certificates, and, where applicable, login credentials used for access control.
• Contract Data: This refers to data collected in connection with a contract we have entered into or in the course of providing our services, such as information regarding the type of contract, the date the contract was concluded, the contract term, contractual services, and other data.

Information provided prior to the conclusion of the contract, information necessary for or used in the fulfillment of the contract (e.g., information regarding billing or customer service), information about feedback (e.g., complaints or satisfaction ratings, etc.), and financial data (e.g., information regarding solvency/creditworthiness, payment reminders, and debt collection). This may also include health data.

• Communication Data: This refers to data generated in the course of communication between us and third parties (e.g., via contact forms, email, telephone, mail, or other means of communication), such as the content of emails or letters, your contact information, and ancillary communication data, as well as, where applicable, a copy of an identification document.
• Technical Data: This refers to data collected when you use our electronic services (e.g., website, Wi-Fi), such as your IP address, information about your device’s operating system, the region, and the time of use. Technical data alone generally does not allow us to identify you.
• Behavioral and Preference Data: This refers to data about your behavior and preferences, such as responses to electronic communications, navigation on the website, interactions with our social media profiles, participation in contests or events, etc., which may be supplemented with information from third parties (including from publicly available sources). For information on tracking, see Section 13.
• Applicant Data: This includes all information you provide to us as part of your application materials, such as information about your education and degrees, grades, your work experience, employment references, and other professional references, as well as your extracurricular activities. In addition, we may obtain references from third parties, provided that you have listed these references or have otherwise given us your consent to do so.
• Other Data: This may include, among other things, the following information and data: data generated in connection with administrative or judicial proceedings (e.g., case files, evidence, etc.), data collected for health protection purposes (e.g.,

collected as part of security measures), photos, videos, or audio recordings that we produce or receive from third parties and in which you are recognizable (e.g., at events, via security cameras, etc.), access data or rights (e.g., as indicated on visitor lists, when you enter certain buildings, or what access rights you have), participation in events or activities (e.g., contests and events), and when you use our infrastructure and systems. Data related to your status as a shareholder or investor with us (e.g., information for various registries, the exercise of your rights, and the conduct of events such as general meetings).

4. WHERE DOES THE DATA COME FROM?

• From You: You provide us with much of the data listed in Section 3 yourself (e.g., when communicating with us, in connection with contracts or our services, through the use of our website and other services, etc.). You are not obligated to provide your data, with exceptions in individual cases (e.g., legal obligations such as legally required identity verification or security measures). However, if you wish to enter into contracts with us or use our services (for yourself or your employer or client), you must provide us with certain data (in particular, master data, contract data, and registration data). When using our website, the processing of technical data is unavoidable. If you wish to gain access to certain systems or buildings, you may need to provide us with registration data. However, with regard to behavioral and preference data, you generally have the option to object or withhold your consent.
• From third parties: To the extent permitted, we may also obtain data from publicly available sources (e.g., debt collection registries, commercial registries, the media, or the Internet, including social media) or from government agencies and other third parties (e.g., credit bureaus,

(address brokers, associations, contractual partners, web analytics services, etc.). This includes, in particular, the following categories: master data, contract data, and other data, as well as all other data categories specified in Section 3 and data from correspondence and meetings with third parties. If you work for an employer, client, or anyone else who has a business relationship with us or otherwise interacts with us, that party may also provide us with data about you.

5. FOR WHAT PURPOSES DO WE PROCESS YOUR DATA?

• Communication: In order to communicate with you (e.g., to respond to inquiries, provide advice, and process contracts), we must process data from you (in particular, communication and master data, as well as registration data in connection with the services you use). If we need or wish to verify your identity, we will collect additional data (e.g., a copy of an ID). For this purpose, we use, in particular, communication data and master data, as well as registration data in connection with the services you use.
• Contract Formation, Management, and Execution: In connection with the initiation, conclusion, and execution of contracts with our visitors (e.g., as part of reservation management), other customers, suppliers, subcontractors, or other contractual partners (e.g., project partners), we process related personal data. To this end, we also process data for credit checks, for establishing and managing customer relationships, for customer service, and for the provision and collection of contractual services (which also includes the involvement of third parties, such as logistics companies, advertising service providers, or credit bureaus, which may in turn provide us with data). We also process data to enforce legal claims arising from contracts (debt collection, legal proceedings, etc.), for accounting purposes, and for

This includes the termination of contracts and public communications. For this purpose, we use, in particular, master data, contract data, and communication data, as well as registration data and technical data (e.g., for digital services), where applicable.

• Marketing Purposes and Customer Relationship Management: For marketing purposes and to manage customer relationships, we process data—for example, to send our visitors and other customers, other contractual partners, and other interested parties personalized advertising (e.g., in print, via email, other electronic channels, or by phone) regarding products, services, and other news from us and from third parties (e.g., product partners), in connection with free offers (e.g., invitations, coupons, etc.), or as part of specific marketing campaigns (e.g., events, contests, etc.). You may opt out of such communications at any time or refuse or revoke your consent to being contacted for advertising purposes by notifying us (Section 2). With your consent, we can tailor our online advertising on the Internet more specifically to you (see Section 13). This also includes interaction with existing customers and their contacts, which can be personalized based on behavioral and preference data. As part of relationship management, we may also operate a customer relationship management (CRM) system in which we store data from visitors, other customers, and other business partners. For marketing purposes and to maintain customer relationships, we process, in particular, communication, registration, behavioral, and preference data.
• Market research, improvement of our services and operations, and product development: To continuously improve our products and services (including our website) and to be able to respond quickly to changing needs, we analyze, for example, how you navigate our website, which products are used by which groups of people and in what ways, and how new products and services can be designed (for further details, see Section 13). This provides us with insights into the market acceptance of existing products and services and the market potential of new ones. To this end, we process, in particular, customer data,

Behavioral and preference data, as well as communication data and information from customer surveys, polls, and studies, and other information—for example, from the media, social media, the Internet, and other public sources. To the extent reasonably feasible, we use pseudonymized or anonymized data for these purposes.

• Registration and security purposes, as well as technical and physical access controls: To access certain offerings and services, you must register; we process data for this purpose. We also collect additional personal data about you while you are using the offering or service. We continuously review and improve the appropriate security of our IT systems and other infrastructure (e.g., buildings). Access controls include, in particular, physical access controls. For security purposes (both preventative and to investigate incidents), we also maintain access logs and visitor lists.
• Compliance with laws, directives, and recommendations from authorities, as well as internal regulations (“Compliance”): In order to comply with laws, we may process personal data (e.g., to combat money laundering, fulfill tax obligations, report foreign guests to the cantonal immigration authorities, or implement health and safety measures). In addition, data processing may occur in connection with internal investigations as well as external investigations (e.g., by a law enforcement or regulatory authority or a commissioned private entity). For this purpose, we process, in particular, master data, contractual data, and communication data; under certain circumstances, however, we may also process behavioral data, technical data, and data from the “other data” categories. These legal obligations may involve Swiss law, but also foreign regulations to which we are subject, as well as self-regulatory measures, industry standards, our own “corporate governance,” and official instructions and requests.
• Risk Management and Corporate Governance: As part of risk management (e.g., to protect against criminal activities) and

We may process personal data in connection with corporate management, including our operational organization (e.g., resource planning) and corporate development (e.g., the acquisition and sale of business units or companies). In this context, we process, in particular, master data, contract data, registration data, and technical data, as well as behavioral and communication data.

• Job Applications: When you apply for a position with us, we collect and process the relevant data for the purpose of reviewing your application, conducting the application process, and—if your application is successful—preparing and finalizing the corresponding contract. For this purpose, we process, in particular, master data and applicant data.
• Other Purposes: These other purposes include, for example, training and educational purposes, administrative purposes (e.g., the management of master data or accounting), the protection of our rights, and the evaluation and improvement of internal processes. The protection of other legitimate interests also falls under these other purposes, which cannot be listed exhaustively. We also process data related to your status as a shareholder or investor in our company (e.g., information for various registries, the exercise of your rights, and the organization of events such as annual general meetings).

6. ON WHAT BASIS DO WE PROCESS YOUR DATA?

Our processing of your data is based—depending on the situation and the purpose of the processing—on the following legal grounds, to the extent necessary:

• Contract: To the extent that we process data for the purpose of entering into and fulfilling contracts that we enter into or have entered into on your behalf, with you, or with your employer, client, or other individuals on whose behalf you act, this also serves as the legal basis on which we process your data.
• Legal Obligations: We may also process your data in accordance with the applicable legal, regulatory, and professional requirements with which we must comply.
• Legitimate Interest: We may process your data based on our legitimate interest or the legitimate interest of a third party. This applies in particular to achieving the purposes and objectives set forth in Section 5 and to implementing related measures. Among other things, we have a legitimate (and overriding) interest in marketing our products and services, as well as in gaining a better understanding of the markets relevant to us and our business (in particular, in the efficient and secure execution of our processes and the further development of our activities), in the efficient and effective management of our company, and in safeguarding the security of our systems, buildings, and our interests vis-à-vis third parties.
• Consent: When we ask for your consent to process your data, this serves as the legal basis on which we process your data. We will inform you of the purpose of the processing. You may revoke your consent at any time by notifying us in writing (by mail or, unless otherwise specified or agreed, by email), effective for the future (see Section 2 for our contact information and Section 13 regarding the revocation of your consent for online tracking). As soon as we have received and processed your notice of withdrawal of consent, we will no longer process your data for the purposes to which you originally consented (unless further processing is permitted on another legal basis).
• Other Legal Bases: In specific cases, we may also process data based on other legal bases. If this is the case, we will inform you on a case-by-case basis.

7. WHAT ARE THE RULES REGARDING PROFILING?

“Profiling” refers to a process in which personal data is processed automatically to analyze personal characteristics or make predictions (e.g., to analyze a person’s personal interests, preferences, and tendencies, or to predict likely behavior). For example, we conduct profiling in connection with reservations and orders on our website (e.g., to determine which other services and products might be of interest to you based on your purchases). To do this, we use, in particular, behavioral and preference data, technical data, and communication data (e.g., your response to advertisements and other communications). Profiling helps us continuously improve our offerings and better tailor them to your individual needs, plan our business activities, determine the likelihood that a transaction is fraudulent, and provide you with better support through our customer service. To improve the quality of our analyses and forecasts, we may also create profiles—that is, link personal data from various sources—to better understand you as an individual with your diverse interests and characteristics. In both cases, we ensure the proportionality and reliability of the results and take measures against any potential misuse.

8. WHO DO WE SHARE YOUR DATA WITH?

In connection with our contracts, the website, our services and products, our legal obligations, or otherwise to protect our legitimate interests and for the other purposes listed in Section 5, we also transfer your personal data to third parties, in particular to the following categories of recipients:

• Service Providers: We work with service providers in Germany and abroad (third parties) who process data about you (i) on our behalf, (ii) jointly with us, or (iii) data that they receive from us

process on their own responsibility (e.g., IT providers, shipping companies, advertising service providers, cleaning companies, security firms, banks, insurance companies, debt collection agencies, credit bureaus, address verification services, consulting firms, or attorneys). For information on the service providers engaged for the website, see Section 13.

• Contractual partners, including customers: This primarily refers to our customers and other contractual partners where the transfer of your data arises from the contract (e.g., because you work for a contractual partner or because they provide services to or for you). This may also include health data. Recipients also include contractual partners with whom we cooperate or who conduct advertising on our behalf. Contractual partners receive, for example, registration data regarding issued and redeemed gift certificates, invitations, etc. The recipients generally process the data under their own responsibility.
• Government Agencies: We may disclose personal data to government agencies, courts, and other authorities (such as the cantonal immigration police) both in Switzerland and abroad if we are legally obligated or authorized to do so, or if it appears necessary to protect our interests. The recipients process the data under their own responsibility.
• Other Individuals: This refers to other cases where the involvement of third parties is necessary for the purposes specified in Section 5. Other recipients include, for example, delivery addresses you have provided or third-party payees, third parties acting in a representative capacity (e.g., your attorney or your bank), or individuals involved in administrative or court proceedings. If we collaborate with media outlets and provide them with material (e.g., photos), you may also be affected under certain circumstances. As part of our business development, we may sell or acquire businesses, business units, assets, or companies, or enter into partnerships, which may also result in the disclosure of data (including yours, e.g., as a customer, supplier, or their representative) to the parties involved in these transactions. In the course of communicating with our competitors,

We may also share data—which may at times pertain to you—with industry organizations, associations, and other bodies. All of these categories of recipients may, in turn, engage third parties, which means your data may also become accessible to them. We can restrict processing by certain third parties (e.g., IT providers), but not by others (e.g., government agencies, banks, etc.). We also allow certain third parties to collect personal data about you on our website and at events we host (e.g., media photographers, providers of tools integrated into our website, etc.). To the extent that we are not significantly involved in this data collection, these third parties are solely responsible for it. If you have any concerns or wish to exercise your data protection rights, please contact these third parties directly. See Section 13 for the website.

9. IS YOUR PERSONAL DATA ALSO TRANSFERRED ABROAD?

We process and store personal data primarily in Switzerland and the European Economic Area (EEA). In isolated cases, however, we may also disclose personal data to service providers and other recipients (see Section 8) who are located outside this area or who process personal data outside this area—in principle, in any country in the world. If a recipient is located in a country without adequate statutory data protection, we contractually oblige the recipient to comply with applicable data protection requirements (for this purpose, we use the European Commission’s revised Standard Contractual Clauses, which are available here: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?), unless the recipient is already subject to a legally recognized framework ensuring data protection and we cannot rely on an exception provision. An exception may apply, in particular, in the case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires such disclosure, provided that you have consented

or if the data in question is information you have made publicly available and you have not objected to its processing. Please also note that data exchanged over the Internet is often routed through third countries. Your data may therefore be transferred abroad even if the sender and recipient are located in the same country.

10. HOW LONG DO WE PROCESS YOUR DATA?

We process your data for as long as required by our processing purposes, the statutory retention periods, and our legitimate interests in processing for documentation and evidentiary purposes, or as long as storage is technically necessary (e.g., in the case of backups or document management systems). Unless there are any legal or contractual obligations to the contrary, we will delete or anonymize your data after the retention or processing period has expired as part of our standard procedures. Unless there are specific legal retention requirements in individual cases, we generally process personal data for the duration of the business relationship or the term of the contract and, thereafter, depending on the applicable legal basis, for an additional five, ten, or more years. This corresponds to the period during which we or third parties may assert legal claims against one another. Ongoing or anticipated legal proceedings may result in processing extending beyond this period. See Section 13.2 for more information on the retention period for cookies.

11. HOW DO WE PROTECT YOUR DATA?

We take appropriate security measures to safeguard the confidentiality, integrity, and availability of your personal data, to protect it against unauthorized or unlawful processing, and to mitigate the risks of loss, accidental alteration, unintended disclosure, or unauthorized access. However, security risks generally cannot be completely ruled out; a certain residual risk is unavoidable.

12. WHAT ARE YOUR RIGHTS?

Under certain circumstances, applicable data protection law grants you the right to object to the processing of your data, particularly for the purposes of direct marketing, profiling for direct marketing, and other legitimate interests in processing. To make it easier for you to control the processing of your personal data, you also have the following rights in connection with our data processing, depending on applicable data protection law:

• The right to request information from us regarding whether we process your data and, if so, what data we process;
• the right to have data corrected if it is inaccurate;
• the right to request the deletion of data;
• the right to request that we provide certain personal data in a commonly used electronic format or transfer it to another data controller;
• the right to withdraw consent, to the extent that our processing is based on your consent;
• the right to request additional information necessary to exercise these rights.

If you wish to exercise the above-mentioned rights with us, please contact us in writing, in person at our offices, or—unless otherwise specified or agreed—by email; our contact information can be found in Section 2. To prevent misuse, we must verify your identity (e.g., with a copy of your ID, unless this can be done by less intrusive means). You also have these rights with respect to other entities that work with us on their own behalf—please contact them directly if you wish to exercise rights related to their processing activities. Information about our key partners and service providers can be found in Section 8; further details are provided in Section 13. Please note that under applicable data protection law, these rights are subject to certain conditions, exceptions, or restrictions (e.g., to protect third parties or trade secrets). We will inform you accordingly if necessary. If you disagree with how we handle your rights or data protection, please notify us or our Data Protection Officer (Section 2). In particular, if you are located in the EEA, the United Kingdom, or Switzerland, you also have the right to file a complaint with your country’s data protection supervisory authority. A list of authorities in the EEA can be found here: https://edpb.europa.eu/aboutedpb/board/members_de. You can contact the UK data protection authority here: https://ico.org.uk/global/contact-us/. You may also contact the Federal Data Protection and Information Commissioner: https://www.edoeb.admin.ch/edoeb/de/home/deredoeb/kontakt/adresse.html.

13. DO WE USE ONLINE TRACKING AND ONLINE ADVERTISING TECHNIQUES?

AND SIMILAR TECHNOLOGIES? On our website (including our newsletter and reservation portal), we use various technologies that allow us and third parties we engage to recognize you during your visit and, in some cases, to track your activity across multiple visits. We use our own tools as well as, at times, third-party services, in particular to improve the functionality or content of our website (e.g., integration of videos or maps), to compile statistics, and to display advertisements. This enables us and authorized third parties to offer you a personalized web experience (e.g., personalized advertising, interactions on social media sites, etc.).

13.1 What Are Cookies and Similar Technologies?

A cookie is a small text file containing an identifier (a string of letters and numbers) that is transmitted between the server and your system. This allows us and third-party providers we engage or with whom we collaborate to recognize visitors to our website and track them across multiple visits and across different websites. Cookies enable the recognition of a specific device or browser and do not necessarily contain information that personally identifies a user. However, personal data that we or third-party providers we engage store about you (e.g., if you have a user account with us or these providers) may be linked to the information stored in cookies and derived from them, and thus potentially to you personally. In addition to cookies, there are other similar technologies, such as pixel tags and social media plug-ins. Pixel tags are small, usually invisible images or pieces of code that are loaded from a server and provide the server operator with certain information (e.g., access to a web page). We also reserve the right to use fingerprinting. Fingerprinting consists of information collected during your visit to the website via

information about the configuration of your device or browser that makes it possible to distinguish your device from other devices. Social media plug-ins are small software components that establish a connection between your visit to our website and a third-party social media platform. The social media plug-in informs the third-party provider that you have visited our website and may transmit cookies to the third-party provider that it previously placed on your web browser. For more information on how these third-party providers use the personal data they collect via social media plug-ins, please refer to their respective privacy policies.

13.2 What Types of Cookies and Similar Technologies Do We Use?

We? The cookies and similar technologies we use on our websites serve the following purposes (similar technologies are included in each case):

• Essential Cookies: Some cookies are essential for using the website and its features. These cookies ensure the website’s basic functionality, such as the ability to navigate from page to page without losing the items in your shopping cart. They also ensure that you remain logged in to the website. These cookies expire after up to 24 months.
• Performance and Analytics Cookies: Performance and analytics cookies collect information about how our website is used and allow us to analyze website usage—for example, which pages are visited most frequently and how visitors navigate our website. These cookies are used to make visiting the website easier and faster and to generally improve the user experience and convenience. For this purpose, we use third-party analytics services. These cookies have an expiration period of up to 24 months.
• Marketing Cookies: Marketing cookies help us and our advertising partners show you ads on our website for offers or

To show you services that may be of interest to you, or to display our advertisements when you continue browsing the Internet after leaving our website—that is, to show you targeted advertising. These cookies expire after 24 months. Details about our third-party providers and advertising partners can be found in the Consent Management System, which is available on the specific website you are currently visiting. In the Consent Management System, you also have the option to disable certain categories of cookies by adjusting the relevant settings. Some of the third-party providers we use may be located outside of Switzerland. Information regarding the transfer of data abroad can be found in Section 9. By consenting to the use of cookies, you acknowledge that your data may be transferred to a country that does not have an adequate level of data protection and accept the risk that your data in the recipient’s country may be subject to access by foreign authorities that do not adhere to adequate data protection regulations. You may revoke your consent to cookies at any time, as explained in Section 13.3. We currently use services from the following service providers and advertising partners (to the extent that they use your data or cookies placed on your device for advertising purposes):

• Google Analytics: Google Ireland (based in Ireland) is the provider of the “Google Analytics” service and acts as our data processor. Google Ireland relies on Google LLC (based in the U.S.) as its data processor (both “Google”). Google uses performance cookies (see above) to track visitor behavior on our website (duration, frequency of page views, geographic origin of the visit, etc.) and, based on this data, generates reports for us on the use of our website. We have configured the service so that visitors’ IP addresses are processed by Google in Europe

are truncated before being forwarded to the U.S. and therefore cannot be traced. We have disabled the “Data Sharing” and “Signals” settings. Although we can assume that the information we share with Google does not constitute personal data for Google, it is possible that Google could use this data for its own purposes to draw conclusions about visitors’ identities, create personalized profiles, and link this data to these individuals’ Google accounts. If you consent to the use of Google Analytics, you are explicitly consenting to such processing, which also includes the transfer of personal data (in particular, website and app usage data, device information, and individual IDs) to the United States and other countries where your data may be accessible to authorities that are not subject to adequate data protection regulations. You can find information on Google Analytics’ privacy policy here: https://support.google.com/analytics/answer/6004245, and if you have a Google Account, you can find further details on Google’s processing of data here: https://policies.google.com/technologies/partner-sites?hl=de.

13.3 How can I control the use of cookies and similar technologies?

Controlling these technologies? Browsers can automatically accept or reject cookies, but they allow you to change these settings. You can also disable or delete cookies that you have previously accepted. Please note that all settings will be lost if you delete all cookies, including the setting to reject cookies, since this setting itself relies on an opt-out cookie having been set. You must configure these settings separately for each browser you use. To learn how to manage cookies in your browser, check your browser’s help menu. If you choose to reject cookies and similar technologies, you can still use our website, but your

Access to some features and sections of our website may be restricted.

14. WHAT DATA DO WE PROCESS ON OUR WEBSITES IN

SOCIAL NETWORKS? We may operate pages and other online presences (“fan pages,” “channels,” “profiles,” etc.) on social networks and other third-party platforms, where we process the data about you described in Section 3 and below. We receive this data from you and the platforms when you contact us through our online presence (e.g., when you communicate with us, comment on our content, or visit our presence). At the same time, the platform providers may analyze your use of our online presences (e.g., the way you interact with us, how you use our online presences, what you view, comment on, or “like”) and process this data together with other data they have about you (e.g., information about your age and gender and other demographic information). In this way, they create profiles about you and statistics on the use of our online platforms. They use this data and these profiles to display our or other advertisements and other personalized content on the platform and to manage behavior on the platform, as well as for market and user research and to provide us and other parties with information about you and the use of our online platforms. To the extent that we are jointly responsible with the provider for certain types of processing, we will enter into a corresponding agreement with the provider. You can obtain information about the essential content of this agreement from the provider. The provider also processes this data for its own purposes, in particular for marketing and market research purposes (e.g., to personalize advertising) and to manage its platforms (e.g., to decide what content to show you), and acts as a separate data controller for this purpose.

We are entitled, but not obligated, to review content before or after it is published on our online platforms, to delete content without notice, and, if necessary, to report it to the provider of the relevant platform. In the event of violations of standards of decency and conduct, we may also notify the provider of the platform on which the relevant user account is located to suspend or delete the account. For more information on data processing by platform operators, please refer to the privacy policies of the respective platforms. There, you can also find out in which countries your data is processed, what rights you have regarding access and deletion, and how you can exercise these rights or obtain further information.

15. CAN THIS PRIVACY POLICY BE CHANGED?

This Privacy Policy is not part of any contract with you. We may update this Privacy Policy at any time. The version published on this website is the most current version. This page was last updated on September 1, 2023. If you have any questions or comments regarding our legal notices or privacy policy, please contact us.

Last update according to the original document: September 1, 2026