Privacy Policy
Version: September 14th 2026
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration below.
2. Hosting and Content Delivery Networks (CDN)
We are hosting the content of our website at the following provider:
External Hosting
This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.
The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.
We are using the following host(s):
Microsoft Azure
Microsoft Ireland Operations Limited
One Microsoft Place, South County Business Park, Leopardstown
Dublin 18
Ireland
Our online offering runs on the following Azure services: Azure Static Web Apps (delivery of the web application), Azure Functions (application backend), Azure Cosmos DB (database), Azure Blob Storage (storage of images and files), Azure Web PubSub (real-time updates in the browser), and Azure Application Insights (operational logging and error diagnostics). The application backend, the database, the content stored by us and the audio and video transmission of the gatherings are operated in Germany (Azure region "Germany West Central", Frankfurt am Main). The delivery of the web application runs in the Azure region "West Europe" (Netherlands), because the service used for it is not offered in the German region. Static components of the web application may additionally be delivered from distributed Microsoft edge locations, and all requests to our website are routed through the Cloudflare content delivery network (see the section "Cloudflare" below).
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Cloudflare
We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).
Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.
The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR).
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
andTheLight GmbH
Penningsfelder Weg 96 A
51069 Köln
Germany
Phone: +49 2291 9015690
E-mail: [email protected]
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded. Other users of our platform and guests of a gathering receive personal data about you only to the extent described in the sections "Registration on this website" and "Intentions and practice" and in section 10 below.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses. The supervisory authority responsible for us is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Postfach 20 04 44, 40102 Düsseldorf, Germany, telephone +49 211 38424-0, e-mail [email protected].
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data, with the exception of their archiving, may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Encrypted payment transactions on this website
Where a paid membership obliges you to provide payment details, you enter those details directly on the payment page of our payment service provider; they do not reach us. That page is operated by the provider and transmitted in encrypted form. The payment methods offered there are those we have enabled for our account with the provider. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. Details are set out under "Payment services" below.
If the connection is encrypted, third parties cannot read the payment details you enter on that page.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
4. Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.
Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.
Our own application sets only technically necessary cookies: for keeping you signed in and ending your session, for securing the sign-in process and the renewed identity check before sensitive account actions, and for remembering the language of the pages you last visited; our hosting provider additionally sets cookies for load distribution. In the local storage of your browser we keep your choice between light and dark mode and your display setting for the week view; while you change your sign-in address, the address you typed is kept in the session storage of your browser until you return from the identity check. These cookies and storage entries require no consent pursuant to § 25 (2) No. 2 TDDDG, because they are strictly necessary to provide the functions you have expressly requested; the sign-in cookies are processed on the basis of Art. 6(1)(b) GDPR, the other cookies on the basis of Art. 6(1)(f) GDPR. The list of the cookies used on this website, with their names, purposes and storage periods, including those that are set only after your consent, is maintained on our cookie policy page, where you can also change your consent at any time.
Server log files
When you use our website, our hosting provider, our content delivery network and our application backend automatically record technical information about each request in log and diagnostic data. The information comprises:
- The address requested, the page from which you came (referrer), and the time and duration of the request
- The type and version of browser used and the operating system, as reported by your browser
- The IP address
We evaluate the log and diagnostic data of our application backend and of the server-side runtime of our website in Azure Application Insights for error diagnosis, for security and for the operation of the website. Application Insights uses the IP address to derive an approximate location (country and city), masks it before it is stored and keeps only that location; diagnostic messages of our application backend may contain technical identifiers of your account and abbreviated forms of your e-mail address (first letter and domain). The data we hold in Application Insights are deleted automatically after 90 days at the latest. Our hosting provider and Cloudflare keep their own access logs for the operation and security of their services under the data processing agreements concluded with them (see the sections "External Hosting" and "Cloudflare" above); Cloudflare processes the IP address in full in order to filter malicious traffic. We do not merge these data with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, log and diagnostic data must be recorded.
Contact form and feedback function
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The same applies to messages you send us via the feedback function; it can be opened from the footer of our pages and also accepts messages without an account. If you are signed in when you submit a contact or feedback message, we store the first and last name from your account and your account identifier together with the message so that we can answer you and so that the message can be deleted from our database together with your account; for messages sent without an account we store only what you enter. Contact and feedback messages are stored in our database and additionally forwarded to our team mailbox via our e-mail service provider (see "Twilio SendGrid" below).
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form or the feedback function shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). Messages linked to your account are deleted from our database together with the account; the copy in our team mailbox remains subject to the preceding sentence. This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
Request by e-mail or telephone
If you contact us by e-mail or telephone, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.
Google Calendar
On this website, signed-in users can add the appointments of their groups (“gatherings”) to their own Google calendar (“Add to calendar”). For this purpose we use Google Calendar. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
This feature only becomes active if you explicitly connect your Google account with our service in Google's authorization dialog. When you use it, we create the respective gathering appointment in your primary Google calendar. Which data our application accesses in the process, how the access tokens are stored, and how you can revoke the connection is described in detail in the following section “Google API Services Usage”.
The legal basis for this processing is your consent pursuant to Art. 6(1)(a) GDPR, which you grant in Google's authorization dialog and can revoke at any time via your Google Account permissions, as well as Art. 6(1)(b) GDPR, insofar as the entry of the appointments is part of providing the service you requested.
Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://cloud.google.com/terms/sccs.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Data processing roles
Google does not process the calendar data on our behalf but as an independent controller under its own privacy policy (https://policies.google.com/privacy); a data processing agreement pursuant to Art. 28 GDPR is therefore not concluded for this purpose.
Google API Services Usage
In addition to the general Google Calendar integration, our application uses Google API Services to provide enhanced functionality. To comply with the Google API Services User Data Policy, we disclose the following regarding our use of your Google User Data:
Data Accessed
Our application accesses the following Google user data:
- Calendar Events: Read and write access to your calendar events (`https://www.googleapis.com/auth/calendar.events`) to create and manage the events you schedule through our service.
- Calendar Read-Only: Read-only access to your calendar list (`https://www.googleapis.com/auth/calendar.calendars.readonly`) to ensure we are adding events to the correct calendar.
Data Usage
We use the accessed Google user data solely for the following purposes:
- To create, update, or manage the calendar appointments you explicitly request through our "Add to Calendar" functionality.
We do not use your Google user data for advertisements, surveillance, or any other personalized or non-personalized purposes unrelated to the core functionality of scheduling appointments.
Data Sharing
We do not share your Google User Data with any third parties, except as required by applicable law. Your data is not sold, rented, or effectively transferred to any other entity for any purpose.
Data Storage & Protection
Your OAuth tokens (Access and Refresh tokens) are stored securely in our database (Azure Cosmos DB). We employ strong encryption (AES-256) to protect these tokens at rest. They are only decrypted when necessary to perform the calendar actions you have authorized.
Data Retention & Deletion
We retain your access and refresh tokens in encrypted form until you delete your account or ask us to remove them. You can revoke our access to your Google account at any time via your Google Account permissions; after revocation the tokens can no longer be used, and they are removed from our systems when your account is deleted or on your request.
Outlook / Microsoft 365 calendar
Signed-in users can also add the appointments of their groups ("gatherings") to their own Microsoft calendar. This feature only becomes active if you explicitly connect your Microsoft account with our service in Microsoft's authorization dialog. In doing so you grant us read and write access to your calendars and read access to your mailbox settings; we use the latter solely to determine your time zone where the group does not supply one. We store the resulting access and refresh tokens in encrypted form until you delete your account. If you revoke the access in the permissions of your Microsoft account, the tokens become unusable; they are removed from our systems when your account is deleted or on your request. Into your calendar we write the title, description, time and duration of the gathering and a link to the group page; we do not read your other appointments. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.
The legal basis is your consent pursuant to Art. 6(1)(a) GDPR, which you grant in Microsoft's authorization dialog and can revoke at any time in the permissions of your Microsoft account, as well as Art. 6(1)(b) GDPR insofar as entering the appointments is part of the service you requested.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing roles
Microsoft does not process the calendar data on our behalf but as an independent controller under its own privacy statement (https://privacy.microsoft.com/en-us/privacystatement); a data processing agreement pursuant to Art. 28 GDPR is therefore not concluded for this purpose.
Registration on this website
You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.
To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.
The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, if necessary, for the initiation of further contracts (Art. 6 (1)(b) GDPR).
eqoah is a group platform, so some of your data is visible to other users. The person who looks after a group you have joined (the moderator) sees your first name and the initial of your last name in the member list and is notified by e-mail in the same form when you join; when a group is handed over, the new moderator is told in the same form who handed the group over. To the other participants of a gathering you are shown in the video room and next to your short messages (real-time text) under your first name and the initial of your last name. Your e-mail address and your full last name are not shown to other users. The legal basis is Art. 6(1)(b) GDPR, as this visibility is part of the service you registered for.
The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.
When an account is deleted, we permanently keep one irreversible technical record of the deletion: a one-way cryptographic hash of the internal account identifier. It contains no name, no email address and no other personal detail, and it cannot be converted back into them. We keep it so that a deleted account can never be re-created automatically by a sign-in session that was still open elsewhere at the moment of deletion; that is, so the deletion stays permanent. The legal basis is our legitimate interest in making account deletions permanent and in honouring your erasure request under Art. 17 GDPR (Art. 6(1)(f) GDPR).
Intentions and practice
As a signed-in user you can record a body intention and a mind intention in free text and mark each day on which you practised. We store the text of your intentions, the date and time at which you set them and the date and time of each practice you marked, together with your account. Setting a new intention does not delete earlier ones; they remain in your history, and individual intentions cannot be deleted separately: all of them are deleted with your account. The text of your intentions is visible only to you; it is not shown to other users.
Other members never see the text of your intentions or your name next to your practice. Your practice days are counted, without your name, in the anonymous daily totals that the members of the intention groups you belong to can see: how many members of the group practised on each of the last seven days. In your account you can choose one of your intention groups as your peer group; the anonymous totals of that group are then shown as a ring on your start page and on a connected device. When you join your first intention group, it is selected as your peer group automatically; you can change or clear the selection in your account at any time, and clearing it only hides the ring on your own start page. When you mark a day as practised, open browser tabs and connected devices of you and of the members of your groups are notified in real time via Azure Web PubSub; these notifications contain no personal data and only prompt the devices to reload the current totals.
The intention fields are free text for your practice intentions. We do not ask you for information about your health and we do not evaluate the content of your intentions; the text is stored and displayed for you only. Please do not enter information about your health or other particularly sensitive information. The legal basis for storing your intentions and practice days and for counting your practice days in the anonymous totals of your groups is Art. 6(1)(b) GDPR (performance of the user contract).
Sign-in service Microsoft Entra External ID
For registration and sign-in on this website we use the identity service Microsoft Entra External ID. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter “Microsoft”).
When you create an account or sign in, your e-mail address, your credentials, and the technical data of the sign-in process (e.g., IP address and time of the sign-in) are processed by Microsoft Entra External ID on our behalf. During sign-up, the service sends a one-time verification code to the e-mail address you provided; self-service password reset works the same way. If you later change your sign-in address, the one-time code confirming the new address is sent by us, not by the identity service; see "Twilio SendGrid" below. Your password is stored exclusively within the identity service and not in our application database.
In exceptional cases, for example if you cannot complete the password reset yourself and ask our support for help, one of our administrators can set a new password for your account in the identity service and communicate it to you outside our platform, by a channel agreed with you. That administrator knows this password until you change it; we learn nothing about your previous password. A change of the new password is not enforced, so we recommend that you change it at your next sign-in.
The processing is carried out for the purpose of implementing the user relationship established by the registration (Art. 6(1)(b) GDPR) and in our legitimate interest in secure, state-of-the-art authentication (Art. 6(1)(f) GDPR).
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Registration with Google
Instead of registering directly on this website, you can register with Google. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Technically, the Google sign-in is brokered through our sign-in service Microsoft Entra External ID (see the section “Sign-in service Microsoft Entra External ID” above): Google confirms your identity to that service, which then signs you in to our website.
To register with Google, you must only enter your Google name and password. Google will identify you and confirm your identity to our website.
When you sign in with Google, we may be able to use certain information in your account to complete your profile with us. You decide whether you want this information to be used and if so, which information it is, within the framework of your Google security settings, which you can find here: https://myaccount.google.com/security and https://myaccount.google.com/permissions.
The data processing associated with Google’s registration is based on our legitimate interest in making the registration process as simple as possible for our users (Art. 6(1)(f) GDPR). Since the use of the registration function is voluntary and the users themselves can decide on the respective access options, no conflicting predominant rights of the data subjects are apparent.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
If you link a Google account to your existing eqoah account, we compare the verified e-mail address of the Google account with the e-mail address of your eqoah account and refuse the link if they differ; this prevents your account from being linked to someone else's Google account.
5. Social media
The social media elements described in this section are not yet integrated on our website; the following descriptions apply from the moment they are. We will only integrate them once you have given your consent for them in our consent banner; until then, no connection to the servers of the respective network is established and no data is transmitted.
We have integrated elements of the social network Facebook on this website. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.
An overview of the Facebook social media elements is available under the following link: https://developers.facebook.com/docs/plugins/.
If the social media element has been activated, a direct connection between your device and the Facebook server will be established. As a result, Facebook will receive information confirming your visit to this website with your IP address. If you click on the Facebook Like button while you are logged into your Facebook account, you can link content of this website to your Facebook profile. Consequently, Facebook will be able to allocate your visit to this website to your user account. We have to emphasize that we as the provider of the website do not receive any information on the content of the transferred data and its use by Facebook. For more information, please consult the Data Privacy Policy of Facebook at: https://de-de.facebook.com/privacy/explanation.
The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.
X (formerly Twitter)
We have integrated functions of the social media platform X (formerly Twitter) into this website. These functions are provided by the parent company X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The branch Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, is responsible for the data processing of individuals living outside the United States.
If the social media element has been activated, a direct connection between your device and X’s server will be established. As a result, X (formerly Twitter) will receive information on your visit to this website. While you use X (formerly Twitter) and the “Re-Tweet” or “Repost” function, websites you visit are linked to your X (formerly Twitter) account and disclosed to other users. We must point out, that we, the providers of the website and its pages do not know anything about the content of the data transferred and the use of this information by X (formerly Twitter). For more details, please consult the X (formerly Twitter) Data Privacy Declaration at: https://x.com/en/privacy.
The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.x.com/en/controller-to-controller-transfers.html.
You have the option to reset your data protection settings on X (formerly Twitter) under the account settings at https://x.com/settings/account.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/2710.
We have integrated functions of the public media platform Instagram into this website. These functions are being offered by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
If the social media element has been activated, a direct connection between your device and Instagram’s server will be established. As a result, Instagram will receive information on your visit to this website.
If you are logged into your Instagram account, you may click the Instagram button to link contents from this website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user account. We have to point out that we as the provider of the website and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.
The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381.
For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://privacycenter.instagram.com/policy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.
The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5448.
This website uses elements of the XING network. The provider is the New Work SE, Am Strandkai 1, 20457 Hamburg, Germany.
Any time one of our sites/pages that contains elements of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns.
The use of this service is based on your consent in accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
For more information on data protection and the XING share button please consult the Data Protection Declaration of Xing at: https://privacy.xing.com/de/datenschutzerklaerung.
6. Analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.
The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Consent management with CookieScript
Our website uses the consent management platform CookieScript to obtain your consent to the storage of certain cookies on your device and to the use of certain technologies, and to document this consent in a manner compliant with data protection law. The provider is Objectis, UAB, Laisves str. 60, LT-05120 Vilnius, Lithuania.
When you enter our website, CookieScript stores a cookie in your browser in which the consents you have granted, or their revocation, are recorded, and the consent status is passed on to the tools integrated via the Google Tag Manager. CookieScript is the first tag executed in the container; analysis tools fire only after you have given the corresponding consent. The consent data are stored until you ask us to delete them, delete the CookieScript cookie yourself, or the purpose for the data storage no longer applies. Mandatory statutory retention periods remain unaffected.
CookieScript is used to obtain the legally mandated consent for the use of cookies and comparable technologies. The legal basis for this is Art. 6(1)(c) GDPR.
On our cookie policy page we display the current list of the cookies in use together with controls to change your consent choices. This list is loaded by a script from the provider's server, which is executed regardless of your consent because it informs you about the cookies in use and lets you manage your consent; in the process your IP address is transmitted to the provider. The legal basis is Art. 6(1)(c) GDPR.
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.
Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://business.safety.google/adscontrollerterms/sccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
IP anonymization
We use Google Analytics in the version Google Analytics 4. According to Google, Google Analytics 4 does not log or store individual IP addresses of users in the European Union, Switzerland, or the United Kingdom: IP addresses collected from users in these regions are dropped before the data is logged, and the data of these users is collected via domains and servers in the EU, Switzerland, and the UK. In Google Analytics 4, this IP handling is an integral part of the service operated by Google; it is not a setting that the website operator can configure or deactivate.
Storage period
Event data that Google stores in connection with cookies, user identifiers or advertising identifiers are deleted after 14 months, user data 14 months after your last activity on our website; aggregated reports are not affected by these periods. Details can be found at https://support.google.com/analytics/answer/7667196?hl=en.
Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Contract data processing
For Google Analytics we have accepted Google’s data processing terms (Google Ads Data Processing Terms), under which Google processes personal data on our behalf in accordance with Art. 28 GDPR. In the account settings we have enabled data sharing with Google for modelling contributions and business insights, technical support and recommendations; the data shared in this way are processed by Google for its own purposes as an independent controller under the Google Measurement Controller-Controller Data Protection Terms.
Microsoft Clarity
This website uses Microsoft Clarity. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, https://learn.microsoft.com/en-us/clarity/faq (hereinafter referred to as “Microsoft Clarity”).
The service described in this section is not yet active on our website; the description applies from the moment it is activated. We will only use it once it has been activated in our tag manager and you have given your consent for it in our consent banner; until then, no data is transmitted to the provider.
Microsoft Clarity is a tool to analyze user patterns on this website. Microsoft Clarity records in particular cursor movements and compiles graphics that show on which parts of the website users are scrolling with great frequency (heatmaps). Microsoft Clarity can also record sessions so that we can watch the use of the site in the form of videos. Moreover, we receive information on the general user conduct within our website.
Microsoft Clarity uses technologies that make it possible to recognize users for the purpose of analyzing user patterns (e.g., cookies or use of device fingerprinting). Your personal data will be archived on Microsoft servers (Microsoft Azure Cloud Service) in the United States.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TDDDG. Such consent may be revoked at any time.
For more details on Microsoft Clarity’s data privacy policy, please see: https://docs.microsoft.com/en-us/clarity/faq.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The service described in this section is not yet active on our website; the description applies from the moment it is activated. We will only use it once it has been activated in our tag manager and you have given your consent for it in our consent banner; until then, no data is transmitted to the provider.
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The service described in this section is not yet active on our website; the description applies from the moment it is activated. We will only use it once it has been activated in our tag manager and you have given your consent for it in our consent banner; until then, no data is transmitted to the provider.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
7. Newsletter
Newsletter data
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
Twilio SendGrid
The newsletter and the e-mail notifications of our platform are dispatched via Twilio SendGrid. The provider is Twilio Inc., 889 Winslow Street, Redwood City, CA 94063, USA. The contracting entity for customers in the European Economic Area (EEA) is Twilio Ireland Limited, 70 Sir John Rogerson's Quay, Dublin 2, D02 R296, Ireland.
Besides the newsletter, this concerns the e-mails our platform sends you, for example notifications concerning your account or your groups and the one-time code when you change your sign-in address, as well as internal notifications of contact-form and feedback submissions to our team inbox.
SendGrid processes for this purpose your e-mail address, your name where provided, the content of the respective e-mail, and technical dispatch data (e.g., delivery and bounce status). If you have subscribed to the newsletter, your e-mail address is additionally stored in a contact list at SendGrid until you unsubscribe; after unsubscribing, your address may be stored in a suppression list to prevent future mailings (see “Newsletter data” above).
The data may be processed on SendGrid servers in the USA. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5394.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
8. Plug-ins and Tools
YouTube with expanded data protection integration
Videos from YouTube are not yet integrated on our website; the following description applies from the moment they are. We will only integrate them once you have given your consent for this in our consent banner; until then, no connection to the servers of YouTube is established.
This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.
We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user's browser, which contain personal data similar to cookies and can be used for recognition. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.
After activating a YouTube video, further data processing operations may be triggered over which we have no influence.
The use of YouTube is based on your consent pursuant to Art. 6(1)(a) GDPR and § 25 (1) TDDDG, which you give in our consent banner and which also covers the storage of cookies or the access to information in your end device within the meaning of the TDDDG; this consent can be revoked at any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
9. eCommerce and payment service providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.
The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.
Data transfer upon closing of contracts for services and digital content
We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.
The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.
Payment services
We integrate payment services of third-party companies on our website. When you take out a paid membership with us, your payment data (e.g. name, payment amount, payment method details) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future.
We use the following payment service within the scope of this website:
Stripe
The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).
Payment for our memberships is processed exclusively through Stripe's hosted checkout page and customer portal. You enter your payment details (e.g., credit card number) directly with Stripe; they are not stored on our servers. When you start a checkout or open the customer portal, we pass your e-mail address, an internal account reference, the chosen membership tier and your language setting to Stripe so that the payment can be assigned to your account and shown to you in your language. Our application automatically receives only the information required to manage your membership, in particular the status of your subscription. Independently of this, our authorized staff can view the customer record held at Stripe in order to administer your membership and handle support enquiries; that record contains, in particular, your name, the billing address you provided to Stripe, your e-mail address and, depending on the payment method, an abbreviated identifier of it, such as the last four digits of your card number. In the customer portal you can view your invoices, change your payment method as well as your name, e-mail address, billing address and telephone number, and cancel your membership. Payment receipts and invoices are e-mailed to you by Stripe; they show your name, your billing address and your e-mail address.
To prevent payment fraud, Stripe evaluates every payment with its own fraud-prevention system (Stripe Radar) and may decline a payment on that basis. Stripe performs this evaluation in its own responsibility on the data it holds about the transaction; the legal basis is the legitimate interest of Stripe and of us in preventing payment fraud (Art. 6(1)(f) GDPR). We do not obtain a credit report or a score from a credit agency.
When you delete your eqoah account, your membership is cancelled. The customer record at Stripe and our own billing records are not deleted together with the account: we are obliged to retain invoices and booking records under commercial and tax law (Art. 6(1)(c) GDPR in conjunction with § 257 HGB and § 147 AO, for up to ten years); during that time their processing is restricted to this purpose, and afterwards they are deleted.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.
Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/de/privacy.
10. Online-based Audio and Video Conferences (Conference tools)
Data processing
We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).
Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.
Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.
Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.
Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.
Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.
Conference tools used
We employ the following conference tools:
Azure Communication Services (eqoah gatherings)
The joint online sessions offered on this website (“gatherings”) are conducted via Azure Communication Services. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland (hereinafter “Microsoft”).
When you take part in a gathering, we create a pseudonymous communication identity for your user account and issue short-lived access tokens for it. Participation takes place in access-restricted rooms whose participant lists are managed by our backend. In the process, connection and metadata (e.g., IP address, device and connection information, time of joining and leaving) as well as the transmitted audio and video streams and any short text messages sent during the session (real-time text) are processed. The audio and video streams are transmitted in real time; we do not create recordings of gatherings.
The gatherings are the core service of our platform; the legal basis for the processing is Art. 6(1)(b) GDPR (performance of the user contract).
Guests without a user account. An administrator can share a guest link for a specific gathering with people who do not have an eqoah account. If you join via such a link, you enter a first name of your choice, which is shown to the other participants as your display name (marked as a guest) for the duration of the gathering, and you accept our Terms of Use and this privacy policy each time you join. We do not store your first name and we do not keep a record of your consent. The pseudonymous communication identity created for that one join is deleted when the link is revoked or, at the latest, three hours after the link expires; a guest link is valid from its creation until three hours after the start of the gathering it was created for. No user account is created. Apart from that, the processing described above for gatherings (connection and metadata, audio and video streams, real-time text) applies in the same way. The legal basis is Art. 6(1)(b) GDPR (performance of the contract on participation in the gathering).
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Microsoft Teams
We use Microsoft Teams for internal meetings of our team and, where you arrange a video call with us, for that call; the gatherings on this website are not conducted via Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.