Privacy policy

Last updated: 24 September 2026

This is a non-binding English translation provided for your convenience. The legally binding version is the German privacy policy.

Emsig Radio (emsigradio.com) is operated by WL Artworld Solutions GmbH, Weydingerstraße 6, 10178 Berlin, Germany. Detailed information about the company and contact details can be found in the imprint.

The protection of your privacy is very important to us. Below, we inform you in detail about how we handle your data.

This privacy policy applies to the website emsigradio.com, the Emsig Radio promo service (customer accounts, listening pages and the recipient area) and the promo mails we send as part of the service.

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website or use the Emsig Radio service. Personal data is any data by which you can be personally identified. For detailed information on data protection, please refer to our privacy policy set out below this text.

Who this policy applies to

Emsig Radio has three groups of users, and each has its own section:

• Visitors to the website (sections 2 to 4).
• Customers: labels, artists and promoters who create an account and commission campaigns or send them themselves (sections 4, 6 and 7).
• Recipients: DJs, radio and press people, playlist curators and bookers who receive promos from us (section 5).

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the Controller” in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may, for example, be data you enter when registering, when signing up for promos or when giving feedback on a release.

Other data is collected automatically when you visit the website, by means of our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time the page was accessed). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure the error-free provision of the website and the service. The remaining data serves to provide the service: managing your account, running and invoicing campaigns and, for recipients, sending you suitable promos and passing your feedback on to the commissioning label.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. In addition, under certain circumstances, you have the right to request the restriction of the processing of your personal data. Furthermore, you have a right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analysis Tools and Third-Party Tools

This website uses no analytics tools, no advertising trackers and no third-party error logging services. Fonts are served from our own servers; no content is loaded from third-party servers when you open our pages. The only third party your browser comes into contact with is the Cloudflare network described in section 2.

2. Hosting and Content Delivery Networks (CDN)

We host the content of our website and our service with the following provider:

Hetzner

The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter “Hetzner”). Our servers are located in Hetzner data centres in Germany. The files of the service are stored there too, in particular the audio files and artwork uploaded by customers, invoices and campaign reports (Hetzner Object Storage, located in Falkenstein). For details, please see Hetzner’s privacy policy: https://www.hetzner.com/legal/privacy-policy/.

The use of Hetzner is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website and provision of our service.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Cloudflare

We use the service “Cloudflare”. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).

Cloudflare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through Cloudflare’s network. This enables Cloudflare to analyze the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies to recognize internet users, which, however, are used solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our web offering as error-free and securely as possible (Art. 6(1)(f) GDPR).

Data transfer to the USA is based on the European Commission’s Standard Contractual Clauses. You can find details and further information on security and data protection at Cloudflare here: https://www.cloudflare.com/privacypolicy/.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. You can obtain further information from the provider at the following link: https://www.dataprivacyframework.gov/participant/5666.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website or the Emsig Radio service, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g. when communicating by email) can have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the Controller

The controller responsible for data processing on this website is:

WL Artworld Solutions GmbH
Weydingerstraße 6
10178 Berlin
Germany

Phone: +49 (0)30 12086092
Email: [email protected]

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage Period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate 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. retention periods under tax or commercial law); in the latter case, deletion takes place after these reasons no longer apply.

General Information on the Legal Bases for 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, where special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), the data processing is additionally based on Section 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the performance 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, we process your data where it is necessary for compliance with a legal obligation, on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of Personal Data

As part of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary in the context of the performance of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in passing it on, or if another legal basis permits the data transfer. When using processors, we pass on the personal data of our customers only on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA 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. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work, or the place of the alleged infringement. This right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done where it is technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may, apart from being stored, only be processed with your consent or for the assertion, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, this site uses SSL/TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Advertising Emails

The use of contact data published within the framework of the imprint obligation to send advertising and information materials not expressly requested is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example through spam emails.

4. Data Collection on This Website

Cookies

Our web pages use only technically necessary cookies. Cookies are small data packets and do not cause any damage to your device. Specifically, we set:

• a session cookie that recognizes your session on the server (login, forms, language setting). It is deleted at the end of your session.
• a cookie holding a security token that protects our forms against misuse by other websites (CSRF protection).
• if you choose “Remember me” when logging in: a persistent cookie that keeps you logged in on this device until you log out.
• during a non-public preview of the service: a cookie that grants access to invited testers.

These cookies are required for the functions you have requested. They are set on the basis of Art. 6(1)(b) and (f) GDPR, and access to your device is permitted without consent under Section 25(2) no. 2 TDDDG. We do not set cookies to analyze your behaviour, advertising cookies or third-party cookies. That is also why this website has no cookie banner: there is nothing we would need your consent for.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• browser type and browser version
• operating system used
• referrer URL
• host name of the accessing computer
• time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website; for this purpose, the server log files must be collected.

Protection Against Abuse

To prevent abuse, we limit the number of requests that can be made from one IP address within a short time, for example when requesting sign-in codes or submitting the promo form. For this purpose your IP address is kept in a counter for a few minutes and then discarded. The legal basis is Art. 6(1)(f) GDPR (legitimate interest in the security of the service).

Enquiries by Email

If you contact us by email, your enquiry including all resulting personal data (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent. Our business email infrastructure is operated by Infomaniak (see section 8).

This data is processed on the basis of Art. 6(1)(b) GDPR, insofar as your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) where this has been requested; consent can be revoked at any time.

The data you send us by email remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions, in particular retention periods, remain unaffected.

Email Delivery via Scaleway

All emails sent from the service, whether sign-in and confirmation codes, invitations, invoices and notifications or the promo mails to recipients, are sent via Scaleway’s Transactional Email service. The provider is Scaleway SAS, 8 rue de la Ville l’Évêque, 75008 Paris, France. We use exclusively the Paris region; the data is processed within the European Union and is not transferred to third countries. Privacy policy: https://www.scaleway.com/en/privacy-policy/.

For this purpose Scaleway processes the recipient address, the content of the mail and technical delivery data. We ask Scaleway whether a mail could be delivered, bounced or was reported as spam, and store that result against the respective send. Our mails contain no tracking pixels; we do not record whether you have opened a mail.

The use of Scaleway is based on Art. 6(1)(f) GDPR. We have a legitimate interest in reliable and secure email delivery.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Registration and Customer Account

Labels, artists and promoters can register on this website to use the service. We use the data entered for this purpose (name, email address, password) only for the purpose of using the service. The mandatory information requested during registration must be provided in full. Otherwise, we will refuse the registration.

Your password is not stored in plain text but as a so-called salted hash. You can additionally protect your account with two-factor authentication (one-time codes from an authenticator app; we store the secret this requires and the recovery codes in encrypted form) or with passkeys, in which case we store only the public key. If a login is rejected, you can have a sign-in code sent to you by email; it is valid for ten minutes. You are responsible for keeping your login details secure.

An account belongs to a team. If you invite further people to your team, we store their email address, the role and who invited them until the invitation has been accepted or has expired.

For important changes, for example to the scope of the offer or in the case of technically necessary changes, we use the email address provided during registration to inform you in this way.

The data entered during registration is processed for the purpose of carrying out the user relationship established by the registration and, if applicable, for the initiation of further contracts (Art. 6(1)(b) GDPR).

The data collected during registration is stored by us as long as you are registered on this website. You can delete your account yourself in the account settings. Statutory retention periods, in particular for invoices, remain unaffected.

5. The Promo Service: Data of Recipients

This section is addressed to DJs, radio and press people, playlist curators, bookers and everyone else who receives promos from us. What we promise you in doing so is set out in the recipient terms; this section sets out which data is processed for it.

How you get on the list

Promo mails are advertising. We send them only with your consent (Art. 6(1)(a) GDPR, Section 7(2) no. 2 of the German Act Against Unfair Competition, UWG). There are three ways onto the list:

• You sign up via the “Get promos” form. We send a confirmation code to the address you entered; the signup only takes effect once you enter it (double opt-in). Nothing is sent before that.
• A curator at Emsig Radio invites you. Nothing is sent then either until you have confirmed the invitation by email.
• In individual cases we document an existing relationship, for example with an editorial team we have worked with for years. This confirmation is given by a named person at our company and is recorded with a date.

For every consent we store when you were invited, when you confirmed, by which route, and which version of the recipient terms applied at the time. A signup that is not confirmed within three months is deleted.

Which data we store

Your profile consists of your name, your email address, what you do (DJ, radio, press, playlist, booking or other), the outlet or medium you work for, country and city, languages, preferred file formats, the genres you do or do not want to hear, labels you do not want to hear from, your lead time before a release, your personal send cap and the notes you give us about your focus. Added to that is which lists (pools) you are on. You can view and change all of this yourself via the link in every promo mail or under “Access”; you do not need an account for that.

Our curators also keep internal notes on which releases suit you. That is our editorial judgement, not a statement about you.

Send caps, quiet hours and unsubscribing

We write to you at most as often as your send cap allows, and not at night or at the weekend. Every promo mail contains an unsubscribe link that works with one click and without logging in; your email client can also trigger the unsubscribe directly (RFC 8058). An unsubscribe takes effect immediately and for all lists. You can also revoke your consent at any time by emailing us. The lawfulness of the data processing carried out until the revocation remains unaffected.

Listening pages

Instead of attachments, every promo mail contains a personal listening link. The link is signed and intended for you alone; whoever holds it can open the page without logging in. For every send we store when the mail was sent and whether it could be delivered, how far into each track you listened (as a total per track, not as a log of individual plays), whether and when you downloaded a track and in which format, and your feedback. No IP addresses are stored on the listening pages, no location is determined and no analytics tools are used.

The legal basis is your consent to the recipient terms (Art. 6(1)(a) GDPR) and our legitimate interest in being able to show the commissioning label what happened with its release (Art. 6(1)(f) GDPR).

Your feedback and who sees it

For every release you can give feedback: a rating, what you intend to do with it (play, chart, review, book or “not for me”) and a comment. The commissioning label sees this feedback together with your name and your outlet in its campaign report; that is the point of the exercise, and the recipient terms say so. You may only be quoted publicly if you expressly allow it when giving feedback (quote permission); without it, your comment stays between you, us and the label.

If you later request the deletion of your data, we remove the text of your feedback; the rating remains as a number with no reference to you. A quote a label has already published with your permission cannot be recalled by us, but we ensure it is not used again.

Personalised downloads (watermarks)

A label can decide for a campaign that downloads are personalised. Every file you download then carries an inaudible watermark that refers to your send. If an unreleased recording is passed on, this makes it possible to establish which send the file came from. It does not change the sound. Whether a campaign is watermarked is stated on the listening page before you download.

The legal basis is the legitimate interest of the label and of us in protecting unreleased recordings (Art. 6(1)(f) GDPR). We delete the watermarked files three months after the campaign closes; the mapping between watermark and send is kept for as long as the send itself.

Suppression list

If you unsubscribe or request the deletion of your data, we store your email address as a cryptographic hash in a suppression list. The hash cannot be turned back into the address, but it allows the same address to be recognized in future, even if a label imports it again later. The suppression list contains no name, no outlet and no history, and is not merged with any other data. It serves solely to ensure you receive nothing further from us; that is in your interest as well as in our interest in complying with statutory requirements (Art. 6(1)(f) GDPR, Section 7 UWG). Storage in the suppression list is not limited in time.

Access and deletion

On request we compile everything we have stored about you in a machine-readable format: your profile with its consent history, your lists, your sends, listening data and feedback. Likewise we delete your data on request, with the exceptions described in this section (suppression list, quotes already published).

Storage periods in the promo service

• Your profile is kept for as long as your consent exists. After an unsubscribe it is deleted six months later; the period leaves time to undo an accidental unsubscribe.
• An unconfirmed signup is deleted after three months.
• Sends with listening data and feedback are deleted 24 months after the respective campaign closes.
• Watermarked download files are deleted three months, streaming copies twelve months after the campaign closes.
• The suppression list is not deleted.

6. The Promo Service: Customers, Campaigns and Payments

Customer and Contract Data

We collect, process and use personal customer and contract data to establish, structure and amend our contractual relationships. This includes your team’s legal name, address and VAT identification number, the data of your labels and artists, your campaigns with brief, audio files, artwork and messages to our curators, your plan, and invoices and payment status. We collect, process and use personal data about the use of this service (usage data) only insofar as this is necessary to enable you to use the service or to invoice you. The legal basis for this is Art. 6(1)(b) GDPR.

The customer data collected is deleted after completion of the order or termination of the business relationship and expiry of any statutory retention periods. We retain invoices for eight years under Section 147 of the German Fiscal Code (AO); they are immutable and exempt from our deletion routines. We delete uploaded audio files at your request; streaming copies of them are deleted twelve months after the campaign closes.

Payment Service Provider Mollie

We process payments for campaigns and plans via Mollie. The provider is Mollie B.V., Keizersgracht 126, 1015 CW Amsterdam, the Netherlands (hereinafter “Mollie”). When you make a payment, your payment data (e.g. card number, IBAN) is processed by the payment service provider for the purpose of payment processing; Emsig Radio does not receive or store any raw payment instrument data. We transmit to Mollie the amount, a description of the order, the invoice number and your language setting, and receive back whether and by which method payment was made. For recurring plan payments Mollie creates a customer profile with a payment mandate for you, whose identifier we store in order to trigger subsequent payments. Mollie’s contractual and privacy provisions apply to these transactions: https://www.mollie.com/privacy.

The payment service provider is used on the basis of Art. 6(1)(b) GDPR (performance of the contract) and in the interest of a payment process that is as smooth, convenient and secure as possible (Art. 6(1)(f) GDPR).

Monitoring of Public Sources

To be able to show you where your release was played or reviewed, we read publicly published sources, such as the playlist feeds of radio stations, and match them against your campaigns. No recipient data is processed in doing so; what is stored is the finding, its source, the time and a link or piece of evidence. Our curators review every finding before it is added to your report. The legal basis is Art. 6(1)(b) and (f) GDPR.

7. Data Processing on Your Behalf: Your Own Contact Lists

You can also use the service for your own contacts, by importing a list or by sharing a link through which interested people sign up with you themselves. For these contacts you are the controller within the meaning of the GDPR, and we process the data on your behalf as a processor pursuant to Art. 28 GDPR. You conclude the required data processing agreement in the platform before the first import is possible; on import we record who confirmed when, where the contacts come from and which version of the agreement applied.

Your contacts are visible to no other customer and are never merged with our own lists. An unsubscribe, however, applies platform-wide: anyone who has unsubscribed once is kept out of a later import as well, via the suppression list (section 5).

If you have received a mail from us as a customer’s contact and wish to request access or deletion, please contact the label that wrote to you; requests that reach us are forwarded, and we assist with answering them.

8. General Business Data Processing

Beyond the processing related to the website and the service, we use the service providers named below for the general business operations of WL Artworld Solutions GmbH. If you contact us in a business capacity as a customer, supplier, business partner or other contact and transmit personal data to us in doing so, this data may be stored, backed up or processed within the following services.

Infomaniak (email, file exchange, video conferencing)

For our business email infrastructure, the exchange of documents (kDrive) and video conferences (kMeet) we use services of Infomaniak Network AG, Rue Eugène Marziano 25, 1227 Les Acacias, Switzerland (hereinafter “Infomaniak”). Switzerland has an adequacy decision from the EU Commission; a transfer of data to Switzerland is therefore permissible under data protection law without separate safeguards. Infomaniak’s privacy policy: https://www.infomaniak.com/en/legal/privacy-policy.

If you contact us by email or are contacted by us by email, the messages exchanged, including the personal data they contain (e.g. name, email address, message content), are stored and processed on Infomaniak’s servers. Insofar as files are exchanged via kDrive in the course of customer contact, the documents exchanged and the contact details of the persons involved are stored there as well. For video conferences via kMeet the provider processes the data given to take part (email address and/or telephone number), the duration, start and end of participation, and the technical data required for the connection (in particular IP address, device type, operating system and browser).

Processing is based on Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures) and Art. 6(1)(f) GDPR (legitimate interest in reliable and efficient business communication). Emails are stored for as long as necessary to handle the respective matter, but at least for the duration of statutory retention periods. A data processing agreement (DPA) is in place with Infomaniak.

Backups

Our systems and the data processed on them are backed up regularly in encrypted form. For this we use the storage of our hosting provider Hetzner (section 2) and Infomaniak Swiss Backup (see above). The legal basis is Art. 6(1)(f) GDPR (legitimate interest in resilience and data security) and, insofar as documents subject to retention obligations are backed up, Art. 6(1)(c) GDPR. A data processing agreement (DPA) is in place with both providers.

Accounting and Bookkeeping

For our bookkeeping and the creation of invoices we use accounting software from Haufe Service Center GmbH, Munzinger Straße 9, 79111 Freiburg, Germany (Haufe Group / Lexware); a data processing agreement (DPA) is in place in this respect. Privacy policy: https://www.lexware.de/datenschutz/. Our ongoing financial and payroll accounting, the preparation of annual financial statements and tax advice are handled by LADM Liesegang Aymans Decker Mittelstaedt & Partner mbB (auditors, tax advisors, lawyers), Arnoldstr. 9, 47906 Kempen, Germany. The data required for this, including customer, contract and invoice data, is processed in the course of this. Insofar as LADM handles ongoing payroll and financial accounting for us under our instructions, this is done on the basis of a data processing agreement; insofar as LADM acts in an advisory capacity on tax matters (in particular the preparation of annual financial statements and tax advice), LADM acts as an independent controller and is subject to professional confidentiality obligations. The legal basis is Art. 6(1)(c) GDPR (fulfilment of obligations under tax and commercial law) and Art. 6(1)(b) and (f) GDPR. No data is transferred to third countries in this context.