PRIVACY POLICY

KLAUS BILICZKY

Preamble

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

The terms used are not gender-specific.

As of: March 12, 2025

Table of contents

• Preamble

• Responsible party

• Overview of processing operations

• Relevant legal bases

• Security measures

• Transfer of personal data

• International data transfers

• General information on data storage and deletion

• Rights of data subjects

• Provision of online services and web hosting

• Use of cookies

• Contact and inquiry management

Responsible person

Klaus Biliczky

Lange Länge 8

91564 Neuendettelsau Deutschland

Email: art@biliczky.de

Overview of processing

The following overview summarizes the types of data processed and the purposes for which they are processed, and refers to the data subjects.

Types of data processed

• Inventory data

• Contact data

• Content data

• Usage data

• Meta, communication, and procedural data

• Log data

Categories of data subjects

• Communication partners

• Users

Purposes of processing

• Communication

• Security measures

• Organizational and administrative procedures

• Feedback

• Provision of our online offering and user-friendliness

• Information technology infrastructure

Relevant legal basis

In order to improve the usability of our website and make it more convenient for users, we use so-called “cookies”, small text files that are stored on your computer and contain information about your use of our website and the Internet. You can prevent cookies from being stored on your computer by adjusting the settings in your browser accordingly. However, this may mean that you will not be able to use our website to its full extent.

Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.

Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interests (Art. 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.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Note on the applicability of the GDPR and Swiss DSG: This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “sensitive personal data” used in the Swiss Data Protection Act, the terms ‘processing’ of “personal data,” “legitimate interest,” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DSG within the scope of the Swiss DSG.

Security measures

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability, and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and responses are made to threats to data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

Transfer of personal data

In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

International data transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons, agencies, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance with legal requirements.

For data transfers to the US, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

This double safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of political or legal changes.

We will inform you whether individual service providers are DPF-certified and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, express consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission:

https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General information on data storage and deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

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

Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing procedures.

If there are several specifications regarding the storage period or deletion periods for a piece of data, the longest period shall always apply.

If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.

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

Further information on processing procedures, processes, and services:

Storage and deletion of data: The following general periods apply to storage and archiving under German law:

10-year retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with (4) HGB).

8 years - Accounting documents, such as invoices and expense receipts (Section 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257 (1) No. 4 in conjunction with (4) HGB).

6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant for taxation purposes, e.g., hourly wage slips, operating statement forms, calculation documents, price tags, but also payroll documents, insofar as they are not already accounting documents, and cash register receipts (Section 147 (1) No. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) No. 2 and 3 in conjunction with (4) HGB).

3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and customary industry practices, will be stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of data subjects

Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you 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 related to such direct marketing.

Right to withdraw consent: You have the right to withdraw your consent at any time.

Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with legal requirements.

Right to rectification: In accordance with legal requirements, you have the right to request that data concerning you be completed or that incorrect data concerning you be rectified.

Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.

Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.

Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the provisions of the GDPR.

Provision of online services and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.

Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Log data (e.g., log files relating to logins or the retrieval of data or access times).

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing: Provision of our online offering and user-friendliness; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.

Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”

Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing operations, procedures, and services:

Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data 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 prevent server overload (especially in the case of malicious attacks, known as DDoS attacks), and to ensure server utilization and stability; legal basis: legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Use of cookies

The term “cookies” refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as to ensure the functionality, security, and convenience of online offerings and to analyze visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain the consent of users in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and retrieval of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.

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

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

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).

Persistent cookies: Persistent cookies remain stored even after the device is closed. This allows, for example, the log-in status to be saved and preferred content to be displayed directly when the user revisits a website. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to the processing in accordance with the legal requirements, including through the privacy settings of their browser.

Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).

Data subjects: Users (e.g., website visitors, users of online services).

Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).

Further information on processing operations, procedures, and services:

Verarbeitete Datenarten: Meta-, Kommunikations- und Verfahrensdaten (z. B. IP-Adressen, Zeitangaben, Identifikationsnummern, beteiligte Personen).

Further information on processing operations, procedures, and services:

Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).

Betroffene Personen: Nutzer (z. B. Webseitenbesucher, Nutzer von Onlinediensten).

Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO). Einwilligung (Art. 6 Abs. 1 S. 1 lit. a) DSGVO).

Further information on processing procedures, methods, and services:

Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers specified in the consent management solution. This procedure is used to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read, and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers specified in the consent management procedure.

Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information is available about the providers of consent management services, the following general information applies: The duration of storage of the consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, details of the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and end device used; legal basis: consent (Art. 6(1)(a) GDPR).

Contact and inquiry management

When contacting us (e.g., by mail, contact form, email, telephone, or social media) and within the scope of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to respond to contact inquiries and any requested measures.

Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.);

contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).

Affected persons: Communication partners.

Purposes of processing:

Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.

Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion.”

Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, processes, and services:

Contact form:

When you contact us via our contact form, by email, or other means of communication, we process the personal data you provide in order to respond to and process your request. This usually includes information such as your name, contact details, and any other information you provide that is necessary for us to process your request appropriately. We use this data exclusively for the stated purpose of contacting and communicating with you; legal basis: fulfillment of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Created with the free Data Protection Generator from Dr. Thomas Schwenke: https://datenschutz-generator.de

Translation from German to English with "Deepl Translator": https://www.deepl.com/de/translator