This is a non-binding English translation. The German text is the legally binding version.

Privacy Policy

Last updated: 7 April 2026

Preamble

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

The terms used are not gender-specific.

Table of Contents

  • Preamble
  • Controller
  • Overview of processing operations
  • Relevant legal bases
  • Security measures
  • Transmission of personal data
  • International data transfers
  • General information on data storage and erasure
  • Rights of data subjects
  • Provision of the online offering and web hosting
  • Use of cookies
  • Registration, login and user account
  • Community functions
  • Single sign-on login
  • Contact and inquiry management
  • Web analytics, monitoring and optimization
  • Presence on social networks (social media)
  • Plug-ins and embedded functions and content
  • Changes and updates
  • Definitions of terms

Controller

Aliaksei Kliuchnikau
Alex-Wedding-Str. 5
10178 Berlin, Germany

Email address: privacy@displayminishub.com

Phone: +49 176 72796131

Imprint: https://displayminishub.com/impressum

Overview of Processing Operations

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

Types of data processed

  • Inventory data.
  • Employee data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication and procedural data.
  • Log data.

Categories of data subjects

  • Employees.
  • Communication partners.
  • Users.
  • Third parties.
  • Whistleblowers.

Purposes of processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Reach measurement.
  • Organizational and administrative procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Login procedures.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Public relations.

Relevant Legal Bases

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

  • Consent (Art. 6(1)(a) GDPR) — The data subject has given consent to the processing of personal data concerning them for one or more specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR) — Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) — Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) — Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data do not override those interests.

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

Reference to the application of the GDPR and the Swiss FADP: This privacy notice serves to provide information both pursuant to the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that, due to broader territorial applicability and intelligibility, GDPR terminology is used. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “particularly sensitive personal data” used in the Swiss FADP, the GDPR terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” are used. The legal meaning of these terms, however, continues to be determined by the Swiss FADP within its scope of application.

Security Measures

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

The measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transfer, availability and segregation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the erasure of data and responses to data threats. We also take the protection of personal data into account during the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.

Truncation of IP address: Where IP addresses are processed by us or by the service providers and technologies used, and the processing of a complete IP address is not necessary, the IP address is truncated (also referred to as “IP masking”). Here, the last two digits, or the last part of the IP address after a dot, are removed or replaced with placeholders. The purpose of truncating the IP address is to prevent or substantially impede the identification of a person on the basis of their IP address.

Securing online connections via TLS/SSL encryption (HTTPS): To protect users’ data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the further developed and more secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form.

Transmission of Personal Data

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

International Data Transfers

Data processing in third countries: To the extent that we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or that this occurs in the context of using third-party services or the disclosure or transmission of data to other persons, entities or companies (which is recognizable from the postal address of the respective provider or where the privacy policy expressly indicates the data transfer to third countries), this is always done in accordance with the legal requirements.

For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized by an adequacy decision of the EU Commission on 10/07/2023 as a secure legal framework. Additionally, we have concluded Standard Contractual Clauses with the respective providers that comply with the requirements of the EU Commission and establish contractual obligations to protect your data.

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

For each individual service provider, we inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding security measures apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the EU Commission’s information offering: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Erasure

We erase personal data that we process in accordance with statutory provisions as soon as the underlying consents are withdrawn or there are no further legal grounds for processing. This applies in cases where the original processing purpose ceases to exist or the data is no longer needed. Exceptions to this rule exist where legal obligations or special interests require longer retention or archiving of the data.

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

Our privacy notices contain additional information on the retention and erasure of data that applies specifically to certain processing activities.

If there are multiple specifications for the retention period or erasure deadlines for a piece of data, the longest period is always decisive. Data that is no longer retained for the originally intended purpose, but for legal requirements or other reasons, is processed exclusively for the reasons that justify its retention.

Retention and erasure of data: The following general periods apply to retention and archiving under German law:

  • 10 years — Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required to understand them (§ 147(1)(1) in conjunction with (3) AO, § 14b(1) UStG, § 257(1)(1) in conjunction with (4) HGB).
  • 8 years — Accounting documents such as invoices and expense receipts (§ 147(1)(4) and (4a) in conjunction with (3) sentence 1 AO and § 257(1)(4) in conjunction with (4) HGB).
  • 6 years — Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, operational accounting sheets, calculation documents, price markings, but also payroll documents insofar as they are not already accounting documents, and cash register tapes (§ 147(1)(2), (3), (5) in conjunction with (3) AO, § 257(1)(2) and (3) in conjunction with (4) HGB).
  • 3 years — Data necessary to consider potential warranty and damages claims or similar contractual claims and rights as well as to handle related inquiries, based on previous business experience and customary industry practices, are stored for the duration of the standard statutory limitation period of three years (§§ 195, 199 BGB).

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

Rights of Data Subjects

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

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain access to such data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with the legal requirements, to demand that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to demand its transmission to another controller.
  • Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Provision of the Online Offering and Web Hosting

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

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved); log data (e.g., log files relating to logins or the retrieval of data or access times). Content data (e.g., text or image messages and contributions and the information relating to them, such as authorship details or time of creation).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Provision of online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web host”); legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the websites and files accessed, the date and time of access, the volume of data transferred, the message about successful retrieval, the browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to avoid server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and to ensure server load and stability; legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from erasure until the respective incident has been finally clarified.
  • Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of emails. For these purposes, the addresses of recipients and senders, as well as further information regarding email dispatch (e.g., the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but (unless an end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume responsibility for the transmission path of emails between the sender and receipt on our server; legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Content delivery network: We use a “content delivery network” (CDN). A CDN is a service with the help of which content from an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet; legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Web hosting by Railway: Our application runs on the infrastructure of Railway Corp., 2261 Market Street #4382, San Francisco, CA 94114, USA. As part of providing the service, Railway processes technically necessary connection data (in particular IP addresses, timestamps, request metadata); service provider: Railway Corp., USA; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://railway.com; privacy policy: https://railway.com/legal/privacy; basis for third-country transfers: Standard Contractual Clauses.
  • Cloudflare R2 (image storage) and Cloudflare CDN: Image and media files for our online offering are stored via Cloudflare R2 and delivered via Cloudflare’s content delivery network. Technically necessary connection data (in particular IP address, time of request, requested content, user agent) is processed by Cloudflare in order to deliver the content securely and performantly and to defend against attacks; service provider: Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.cloudflare.com; privacy policy: https://www.cloudflare.com/privacypolicy/; basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses.
  • Error monitoring via Honeybadger: We use Honeybadger to detect, diagnose and remediate technical errors. In the event of a server-side error, error details (e.g., stack trace, affected code path) and technical request metadata (in particular IP address, user agent, time) are transmitted to Honeybadger. This data is used exclusively for the stability and security of our online offering; service provider: Honeybadger Industries LLC, 8 The Green, Suite A, Dover, DE 19901, USA; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.honeybadger.io; privacy policy: https://www.honeybadger.io/legal/privacy/; basis for third-country transfers: Standard Contractual Clauses.

Use of Cookies

The term “cookies” refers to functions that store information on users’ devices and read information from them. Cookies can also be used in connection with various concerns, e.g., for purposes of functionality, security and convenience of online offerings, as well as for the creation of analyses of visitor flows. We use cookies in accordance with statutory provisions. To this end, we obtain users’ consent in advance where required. Where consent is not necessary, we rely on our legitimate interests. This applies if storing and reading information is essential to be able to provide expressly requested content and functions. These include, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We provide clear information on its scope and which cookies are used.

Notes on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., in the context of obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General notes on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also object to processing in accordance with the legal requirements, including via their browser’s privacy settings.

  • Types of data processed: Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further notes on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent (Klaro, self-hosted): As our consent management solution we use Klaro. Klaro is open-source software that we self-host on our own servers (or via our hosting provider Railway). No transmission of consent data to third parties takes place. Consent is stored client-side in a cookie and additionally in a tamper-protected server-side audit log to provide proof of consent in accordance with Art. 7(1) GDPR. We use a consent management solution in which the user’s consent to the use of cookies or to the procedures and providers mentioned within the consent management solution is obtained. This procedure serves to obtain, log, manage and withdraw consents, in particular relating to the use of cookies and comparable technologies that are used to store, read and process information on users’ devices. Within this procedure, users’ consents to the use of cookies and the related processing of information, including the specific processing operations and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and withdraw their consents. The declarations of consent are stored in order to avoid having to repeat the request and to provide proof of consent in accordance with the legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies, in order to be able to assign the consent to a specific user or their device. Unless specific information is provided about the providers of consent management services, the following general information applies: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., relevant categories of cookies and/or service providers) and information about the browser, system and device used; legal bases: Consent (Art. 6(1)(a) GDPR).

Registration, Login and User Account

Users can create a user account. As part of registration, users are informed of the required mandatory information and this is processed for the purposes of providing the user account on the basis of contractual obligation. The data processed includes in particular login information (username, password and an email address).

Within the scope of using our registration and login functions and using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of users in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by email about processes that are relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and contributions and the information relating to them, such as authorship details or time of creation); usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Log data (e.g., log files relating to logins or the retrieval of data or access times).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; organizational and administrative procedures. Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”. Erasure after termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Registration with pseudonyms: Users may use pseudonyms instead of real names as usernames; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • Age declaration and youth protection (JMStV): As part of registration we collect an age declaration from users (age confirmation or age bracket). This information serves compliance with the German Youth Media Protection Treaty (Jugendmedienschutz-Staatsvertrag, JMStV) and our terms of use, in particular to enforce the minimum age for using our online offering and to age-gate or filter content with maturity classifications (e.g., content with the categories “nudity”, “gore” or “sexual”). Based on the age declaration, users are granted or denied access to certain content; no further evaluation of the age declaration takes place. The age declaration is stored for the duration of the user account and removed upon its deletion; legal bases: Legal obligation (Art. 6(1)(c) GDPR in conjunction with JMStV), Legitimate interests (Art. 6(1)(f) GDPR).
  • Profiles of users are not public: User profiles are not publicly visible or accessible.
  • Erasure of data after termination: When users have terminated their user account, their data relating to the user account will be erased, subject to a legal permission, obligation or consent of the users; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • No retention obligation for data: It is the responsibility of users to back up their data prior to the end of the contract in the event of termination. We are entitled to irretrievably delete all of the user’s data stored during the term of the contract; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Community Functions

The community functions we provide allow users to engage in conversations or otherwise exchange with each other. Please note that the use of community functions is only permitted in compliance with applicable law, our terms and guidelines and the rights of other users and third parties.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.). Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures. Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • User contributions are public: Contributions and content created by users are publicly visible and accessible; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • Storage of data for security purposes: Contributions and other inputs by users are processed for the purposes of community and conversation functions and, subject to legal obligations or legal permission, are not disclosed to third parties. A disclosure obligation may arise in particular in the case of unlawful contributions for the purposes of legal prosecution. We point out that, in addition to the content of contributions, their time and the IP address of the users are also stored. This is done in order to be able to take appropriate measures to protect other users and the community; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • Right to erase content and information: The erasure of contributions, content or information of users is permissible after a proper balancing of interests to the extent necessary, insofar as there are concrete indications that they constitute a breach of statutory rules, our specifications or rights of third parties; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).
  • Protection of own data: Users themselves decide which data they disclose about themselves within our online offering. For example, when users provide information about themselves or take part in conversations. We ask users to protect their data and to publish personal data only with care and only to the extent necessary. In particular, we ask users to note that they must especially protect their access data and use secure passwords (i.e., above all, character combinations that are as long and random as possible); legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Single Sign-On Login

“Single sign-on” or “single sign-on login or authentication” refers to procedures that allow users to log in to our online offering using a user account from a single sign-on provider (e.g., a social network). The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the necessary access data in the corresponding online form, or are already logged in with the single sign-on provider and confirm the single sign-on login via a button.

Authentication takes place directly with the respective single sign-on provider. As part of such authentication, we receive a user ID with the information that the user is logged in under this user ID with the respective single sign-on provider, and an ID that cannot be used by us for other purposes (so-called “user handle”). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data sharing chosen as part of authentication, and on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user’s choice, this may include various data, but as a rule it is the email address and the username. The password entered as part of the single sign-on procedure with the single sign-on provider is neither visible to us nor stored by us.

Users are asked to note that their data stored with us can be automatically synchronized with their user account with the single sign-on provider, but this is not always possible or actually done. If, for example, users’ email addresses change, they must change them manually in their user account with us.

We may use single sign-on, where agreed with users, in connection with or prior to performance of a contract, where users have been asked to do so on the basis of consent, and otherwise on the basis of our legitimate interests and the interests of users in an effective and secure login system.

If users decide that they no longer wish to use the connection of their user account with the single sign-on provider for the single sign-on procedure, they must remove this connection within their user account with the single sign-on provider. If users wish to delete their data with us, they must terminate their registration with us.

  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; login procedures. Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”. Erasure after termination.
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.google.de; privacy policy: https://policies.google.com/privacy; basis for third-country transfers: Data Privacy Framework (DPF). Opt-out: settings for the display of advertising: https://myadcenter.google.com/.

Contact and Inquiry Management

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

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and contributions and the information relating to them, such as authorship details or time of creation). Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Communication partners.
  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further notes on processing operations, procedures and services:

  • Contact form: When contacting us via our contact form at https://displayminishub.com/report-issue, by email or other communication channels, we process the personal data transmitted to us in order to respond to and process the respective request. This generally includes information such as name, contact information and, where applicable, further information that is communicated to us and is necessary for the appropriate processing. We use this data exclusively for the stated purpose of contacting us and communication; legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Web Analytics, Monitoring and Optimization

Web analytics (also referred to as “reach measurement”) serves the evaluation of visitor flows on our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are used most frequently, or invite reuse. Likewise, it is possible for us to understand which areas need optimization.

In addition to web analytics, we may also use test procedures, e.g., to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized into a usage process, may be created and information stored in a browser or device and then read for these purposes. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information about times of use. Insofar as users have consented to the collection of their location data vis-à-vis us or vis-à-vis the providers of the services we use, the processing of location data is also possible.

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. As a general rule, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimization, but rather pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number contains no unique data such as names or email addresses. It serves to assign analytics information to a device in order to recognize what content users have called up within one or different usage processes, what search terms they have used, have called these up again or have interacted with our online offering. Likewise, the time and duration of use are stored, as well as the sources of users referring to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users with information from the use of various devices are created, with cookies being used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics does provide coarse geolocation data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, accessible or used for any other purposes. When Google Analytics collects measurement data, all IP queries are carried out on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Consent (Art. 6(1)(a) GDPR); website: https://marketingplatform.google.com/about/analytics/; security measures: IP masking (pseudonymization of the IP address); privacy policy: https://policies.google.com/privacy; data processing agreement: https://business.safety.google/adsprocessorterms/; basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); opt-out: opt-out plugin: https://tools.google.com/dlpage/gaoptout, settings for the display of advertising: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).

Presence on Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We point out that user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, the enforcement of users’ rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and the resulting interests. The latter may in turn be used, e.g., to place advertisements within and outside the networks that presumably correspond to the interests of users. For these purposes, cookies are usually stored on users’ computers, in which user behavior and interests are stored. In addition, data can be stored in the usage profiles independently of the devices used by users (in particular, if they are members of the respective platforms and logged in there).

For a detailed description of the respective forms of processing and opt-out options, we refer to the privacy statements and information of the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be most effectively asserted with the providers. Only the latter have access to user data and can directly take appropriate measures and provide information. If you nevertheless need help, you can contact us.

  • Types of data processed: Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., text or image messages and contributions and the information relating to them, such as authorship details or time of creation). Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Communication; feedback (e.g., collecting feedback via online form). Public relations.
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”.
  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Instagram: Social network, allows the sharing of photos and videos, commenting and favoriting of contributions, sending of messages, subscribing to profiles and pages; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com; privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).

Plug-ins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of users, since they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content or functions. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, but may also be combined with such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., page views and duration of visits, click paths, intensity and frequency of use, types of devices and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; marketing. Profiles with user-related information (creation of user profiles).
  • Retention and erasure: Erasure as described in the section “General information on data storage and erasure”. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further notes on processing operations, procedures and services:

  • Integration of third-party software, scripts or frameworks (e.g., jQuery): We integrate software into our online offering that we retrieve from the servers of other providers (e.g., function libraries that we use for the purpose of displaying or user-friendliness of our online offering). In this process, the respective providers collect the IP address of users and may process this for purposes of transmitting the software to the user’s browser as well as for security purposes and for the evaluation and optimization of their offering; legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Instagram plug-ins and content: Instagram plug-ins and content — these can include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt as part of a transmission (but not the further processing) of “event data” that Facebook collects via functions of Instagram (e.g., embedding functions for content) executed on our online offering or receives as part of a transmission for the following purposes: a) display of content as well as advertising information that corresponds to the presumed interests of users; b) delivery of commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) improvement of ad delivery and personalization of functions and content (e.g., improvement in recognizing which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Controller Addendum”) which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, send information requests or erasure requests directly to Facebook). Note: When Facebook provides us with measurements, analyses and reports (which are aggregated, i.e., do not contain information on individual users and are anonymous to us), this processing is not carried out in the context of joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”), the “Data Security Terms” and, with regard to processing in the USA, on the basis of Standard Contractual Clauses (“Facebook EU Data Transfer Addendum”). The rights of users (in particular to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; legal bases: Legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com. Privacy policy: https://privacycenter.instagram.com/policy/.

Changes and Updates

We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and we ask you to verify the information before contacting them.

Our competent supervisory authority:

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Alt-Moabit 59-61, 10555 Berlin
Phone: +49 30 13889-0
Email: mailbox@datenschutz-berlin.de

Definitions of Terms

This section provides an overview of the terminology used in this privacy policy. Insofar as the terms are defined by law, their statutory definitions apply. The following explanations, on the other hand, are intended primarily to aid understanding.

  • Employees: Employees are persons who are in an employment relationship, whether as workers, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer’s obligation to pay the employee remuneration while the employee performs their work. The employment relationship comprises various phases, including establishment (when the employment contract is concluded), execution (when the employee carries out their work), and termination (when the employment relationship ends, whether by dismissal, termination agreement or otherwise). Employee data is all information relating to these persons in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank data, working hours, leave entitlements, health data and performance evaluations.
  • Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between persons and services, institutions or systems by enabling unique assignment and communication.
  • Content data: Content data includes information generated in the course of the creation, editing and publication of content of all kinds. This category of data may include texts, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates.
  • Contact data: Contact data are essential information that enables communication with persons or organizations. They include, among other things, telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
  • Meta, communication and procedural data: Meta, communication and procedural data are categories that contain information about the way data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. This may include details on file size, creation date, author of a document and modification histories. Communication data captures the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, transaction logs and activity logs, as well as audit logs used to track and verify operations.
  • Usage data: Usage data refers to information that captures how users interact with digital products, services or platforms. This data encompasses a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and which paths they navigate through an application. Usage data may also include the frequency of use, time stamps of activities, IP addresses, device information and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and possible problem areas within digital offerings.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, encompasses any kind of automated processing of personal data that consists in using such personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or whereabouts). For profiling purposes, cookies and web beacons are often used.
  • Log data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as time stamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used for analyzing system problems, security monitoring or for creating performance reports.
  • Reach measurement: Reach measurement (also referred to as web analytics) serves the evaluation of visitor flows on an online offering and may include the behavior or interests of visitors in certain information, such as content of websites. With the help of reach analysis, operators of online offerings can, for example, recognize at what time users visit their websites and what content they are interested in. As a result, they can, for example, better adapt the content of their websites to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, whether collection, evaluation, storage, transmission or erasure.

Based on a German privacy policy created with the free Datenschutz-Generator.de by Dr. Thomas Schwenke. Edited by the controller (additions covering, among other things, web hosting by Railway, image storage and CDN by Cloudflare, error monitoring by Honeybadger, consent management with Klaro, the contact form at /report-issue, and age declaration and youth protection under the German JMStV). This English text is a non-binding translation prepared by the controller for accessibility; the German version remains the legally binding document.