Privacy Policy

GDPR-compliant data processing and your rights

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. This 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.

Last updated: September 30, 2025

Data Controller

digitflow GmbH

Represented by: Managing Director Armin Pfauser

Luxemburger Strasse 148

54294 Trier

Germany

Authorized representatives: Armin Pfauser.

Email address: office@digitflow.de.

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Data Processed

  • Master data (e.g., names, addresses).
  • Content data (e.g., entries in online forms).
  • Contact data (e.g., email, phone numbers).
  • Meta/communication data (e.g., device information, IP addresses).
  • Usage data (e.g., visited websites, interest in content, access times).
  • Contract data (e.g., subject matter of contract, term, customer category).

Categories of Data Subjects

  • Business and contractual partners.
  • Prospective customers.
  • Communication partners.
  • Customers.
  • Users (e.g., website visitors, users of online services).

Purposes of Processing

  • Provision of our online offering and user-friendliness.
  • Direct marketing (e.g., by email or postal).
  • Feedback (e.g., collecting feedback via online form).
  • Contact requests and communication.
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Management and response to inquiries.

Applicable Legal Bases

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

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given consent to the processing of personal data relating to them for a specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 data protection regulations apply in Germany. This includes in particular the Federal Data Protection Act (BDSG). The BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. State data protection laws of the individual federal states may also apply.

Security Measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

These measures include in particular securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, securing availability and separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data and responses to data threats. We also consider the protection of personal data in the development or selection of hardware, software and procedures in accordance with the principle of data protection by design and by default.

SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Subject to express consent or contractually or legally required transmission, we only process or have data processed in third countries with a recognized level of data protection, with contractual obligations through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en

Deletion of Data

The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Within the framework of our data protection information, we may provide users with further information on the deletion and retention of data that are specific to the respective processing procedures.

Use of Cookies

Important note: Our website currently does NOT use any cookies for analytics or marketing purposes.

Cookies are small text files stored by your browser. If we use cookies in the future, we will inform you and, if necessary, obtain your consent.

Technically necessary cookies: Should we use technically necessary cookies in the future (e.g., for session management), this will be done on the basis of Art. 6 para. 1 lit. f GDPR.

Business Services

We process data of our contractual and business partners, e.g., customers and prospective customers (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships and related measures and in the context of communication with contractual partners (or pre-contractually), e.g., to respond to inquiries.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information and corporate organization. We only pass on the data of the contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the persons concerned (e.g., to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners are informed about further forms of processing, e.g., for marketing purposes, within the framework of this privacy policy.

We inform contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g., in online forms, by special marking (e.g., colors) or symbols (e.g., asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for archiving reasons required by law (e.g., for tax purposes, generally 10 years). Data disclosed to us by the contractual partner within the framework of an order is deleted in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between users and providers.

Provision of Online Offering and Web Hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed in the context of providing the hosting offering may include all information relating to users of our online offering that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to deliver the contents of online offerings to browsers, and all entries made within our online offering or from websites.

Collection of access data and log files: We (or our web hosting provider) collect data on every 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, 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.

Server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.

Web Hosting Provider

Our web hosting is provided by:

Uberspace

Jonas Pasche

Kaiserstrasse 15

55116 Mainz

Germany

Website: https://uberspace.de

Privacy policy: https://uberspace.de/privacy

The hosting provider processes data generated when visiting our website (IP addresses, access times, etc.) on our behalf. The servers are located exclusively in Germany. Processing is carried out on the basis of a data processing agreement in accordance with Art. 28 GDPR.

Legal basis: Processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in the reliable and secure operation of our website.

Contact and Inquiry Management

When contacting us (e.g., via contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to contact requests as well as the management of contact and inquiry data within the framework of contractual or pre-contractual relationships is carried out for the fulfillment of our contractual obligations or for responding to (pre-)contractual requests and otherwise on the basis of legitimate interests in responding to requests and maintaining user or business relationships.

Contact Form with Formtaxi

For our contact form, we use the service Formtaxi, a GDPR-compliant form service.

Provider:

Formtaxi.com

Operated by: Leander Lenzing & Alexander Weiss GbR

Germany

Website: https://form.taxi

Privacy policy: https://form.taxi/privacy

Processed data: When you use our contact form, the data you enter (name, email address, message, etc.) is processed via Formtaxi and forwarded to us. Data processing takes place exclusively on servers in Germany.

Purpose: The use of Formtaxi serves the secure and GDPR-compliant processing of your contact requests. Formtaxi ensures that your data is transmitted encrypted and offers additional security features such as spam protection.

Legal basis: Processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in the secure and efficient processing of your contact requests.

Data processing agreement: We have concluded a data processing agreement with Formtaxi in accordance with Art. 28 GDPR. Formtaxi processes your data exclusively according to our instructions.

Web Analytics with Matomo (On-Premise)

Reach Measurement and Web Analysis

We use the open-source analysis tool Matomo for reach measurement and optimization of our website. Matomo is operated by us on German servers (on-premise hosting). There is NO data transfer to third parties or external services.

Technology Used:

  • Software: Matomo (formerly Piwik), open-source web analytics platform
  • Hosting: Own servers in Germany under our complete control
  • Software provider: InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand (Note: InnoCraft is only the software developer. There is NO data transfer to New Zealand or to InnoCraft. All data remains exclusively on our German servers.)

Scope of Data Processing

With each access to our website, we automatically collect the following data:

Anonymized IP address: We truncate your IP address by 2 bytes (e.g., 192.168.178.123 becomes 192.168.xxx.xxx). Identification of individual persons is technically impossible.

Visited pages: Which pages you visit and how long you stay on them

Referrer website: From which website you came to us

Browser and device information: Browser type and version, operating system, device type (desktop, tablet, smartphone)

Technical data: Screen resolution, time zone, plugins used (if transmitted by the browser)

Date and time: Time of page access

No Cookies – Completely Anonymous

Important: We do NOT use any cookies or comparable tracking technologies when using Matomo. Data collection is completely anonymous and without personal reference. There is no merging of data with other data sources. Through the combination of IP anonymization (2 bytes) and the waiver of cookies, identification of individual users is technically impossible. The collected data is completely anonymized within the meaning of the GDPR.

Purpose of Data Processing

We use Matomo exclusively for the following purposes:

  • Analysis of the use of our website for continuous improvement
  • Optimization of user-friendliness and user guidance
  • Error analysis and technical optimization
  • Evaluation of the effectiveness of our content

Storage Period

The data collected by Matomo is stored as follows:

Raw data (server logs): Automatic deletion after 180 days

Aggregated statistics: Retention for a maximum of 24 months for comparison purposes

After these periods expire, the data is automatically and irrevocably deleted.

Legal Basis

Data processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR (legitimate interest). Our legitimate interest lies in the analysis of the use of our website to optimize our offering and to improve user-friendliness.

Since data collection is completely anonymized (IP anonymization + no cookies), no user consent is required. The legitimate interest in web analysis outweighs the interests of users, as no personal data within the meaning of the GDPR is processed.

Your Rights – Opt-out Possible at Any Time

You can object to data collection by Matomo at any time with effect for the future. In this case, an opt-out cookie will be set in your browser, which signals Matomo not to collect your visits anymore.

Note: If you delete your cookies, the opt-out cookie will also be deleted and you will need to declare the objection again.

Opt-out of Matomo tracking:

Data Recipients and Sharing

There is NO transfer of your data to third parties. All collected data remains exclusively on our own servers in Germany. There is no access by external service providers or the software developers of Matomo.

No data transfer to third countries: Since we host Matomo ourselves and do not use cloud services, there is no transfer to third countries outside the EU/EEA.

Further Information

Further information on data protection at Matomo can be found at: https://matomo.org/privacy/

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes in the data processing carried out by us 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, please note that addresses may change over time and please check the information before contacting us.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations are intended primarily to aid understanding. The terms are sorted alphabetically.

Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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 (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

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.

Processing: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether collecting, evaluating, storing, transmitting or deleting.

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 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 Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If 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 consent given at any time.

Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and information about this data as well as further information and a copy of the data in accordance with legal requirements.

Right to rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with legal requirements.

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

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

Right to lodge a complaint with a supervisory authority: In accordance with legal requirements 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 of your habitual residence, 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.