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Data Protection

DATA PROTECTION

Privacy Policy

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). The terms used are not gender-specific. As of: September 30, 2025

Table of Contents

Controller

Frozen Partners Isabeau Rohde Stappweg 37 47475 Kamp-Lintfort Email address: info@frozen-partners.de Phone: 01737005000

Overview of Processing Activities

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.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication, and process data.
  • Log data.

Categories of Data Subjects

  • Communication partners.
  • Users.

Purposes of Processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Applicable Legal Bases

Applicable Legal Bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or establishment. Furthermore, if more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.
  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their 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 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National Data Protection Regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special provisions regarding the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply. National Data Protection Regulations in Austria: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Austria. This includes, in particular, the Federal Act on the Protection of Natural Persons with regard to the Processing of Personal Data (Datenschutzgesetz – DSG). The Data Protection Act contains special provisions regarding the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases.

Security Measures

In accordance with legal requirements and taking into account the state of the art, implementation costs, the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and separation of data. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default. Securing online connections with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use 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 transferred between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transfer of Personal Data

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

International Data Transfers

Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transferring data to other persons, entities, or companies (which can be identified by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is always done in compliance with legal requirements. For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on 2023-07-10. In addition, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data. This dual safeguard ensures comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the DPF, the standard contractual clauses will act as a reliable fallback option. This way, we ensure that your data remains adequately protected even in the event of any political or legal changes. For individual service providers, 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 U.S. 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 consents, or legally required transfers. Information on third-country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original processing purpose ceases to apply or the data is no longer required. Exceptions to this rule exist if 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 deletion of data that specifically applies to certain processing activities. If there are multiple indications regarding the retention period or deletion deadlines for a piece of data, the longest period always applies. Data that is no longer retained for its originally intended purpose but due to legal requirements or other reasons will be processed by us exclusively for the reasons justifying its retention. Retention and Deletion 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 for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
  • 8 years – Accounting vouchers, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO, as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
  • 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already accounting vouchers and cash register tapes (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
  • 3 years – Data that is necessary to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Retention and Deletion of Data: The following general periods apply to retention and archiving under Austrian law:
  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices, as well as all necessary work instructions and other organizational documents (Federal Tax Code (BAO §132), Austrian Commercial Code (UGB §§190-212)).
  • 6 years – Other business documents: Received commercial or business letters, copies of sent commercial or business letters, and other documents, insofar as they are relevant for tax purposes. These include, for example, hourly wage slips, cost accounting sheets, calculation documents, price labels, and payroll documents, insofar as they are not already accounting vouchers and cash register tapes (Federal Tax Code (BAO §132), Austrian Commercial Code (UGB §§190-212)).
  • 3 years – Data that is necessary to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB).
Commencement of period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within which data is stored, the event triggering the period is the effective date of termination or other cessation of the legal relationship.

Rights of Data Subjects

Rights of Data Subjects under the GDPR: As data subjects, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw given consents at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with legal requirements, to demand the completion of incomplete personal data concerning you or the rectification of inaccurate personal data concerning you.
  • Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to demand that personal data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to demand the restriction of processing of the data.
  • Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with legal requirements, or to transmit those data to another controller.
  • Right to lodge a complaint with 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 relating to you infringes the GDPR.

Provision of the Online Offering and Web Hosting

We process user data to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the users’ browser or end device.
  • Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons); Log data (e.g., log files concerning logins or data retrieval or access times). Content data (e.g., textual or visual messages and contributions, as well as related information, such as authorship details or time of creation).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures.
  • Storage and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures, and services:
  • Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 accessed web pages and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and also to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Data deletion: 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 are exempt from deletion until the final clarification of the respective incident.
  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.hetzner.com; Privacy Policy: https://www.hetzner.com/de/rechtliches/datenschutz. Data Processing Agreement: https://docs.hetzner.com/de/general/general-terms-and-conditions/data-privacy-faq/.
  • WordPress.com: Hosting and software for the creation, provision, and operation of websites, blogs, and other online offerings; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).

Use of Cookies

The term “cookies” refers to functions that store and read information on users’ end devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online offerings, as well as for creating analyses of visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the users’ consent in advance, if required. If consent is not necessary, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We clearly inform about their scope and which cookies are used. Notes on data protection legal bases: Whether we process personal data using 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 duration: With regard to storage duration, 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 end device (e.g., browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the end 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 on the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are persistent and the storage duration can be up to two years.
General notes on revocation and objection (opt-out): Users can revoke their given consents at any time and also declare an objection to the processing in accordance with legal requirements, including via their browser’s privacy settings.
  • Types of data processed: Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures, and services:
  • Processing of cookie data based on consent: We use a consent management solution that obtains users’ consent for the use of cookies or for the procedures and providers mentioned within the consent management solution. This procedure serves to obtain, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed for storing, reading, and processing information on users’ end devices. Within this procedure, users’ consents for the use of cookies and the associated 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 revoke their consents. The consent declarations are stored to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. Storage takes place server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information about the providers of consent management services is available, the following general notes apply: 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 end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by mail, contact form, email, phone, or via social media) and within the scope of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to answer contact inquiries and any requested measures.
  • Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or visual messages and posts, as well as information relating to them, such as authorship details or time of creation); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data subjects: Communication partners.
  • Purposes of processing: Communication; Organizational and administrative procedures; Feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
  • Storage and deletion: Deletion according to the information in the section “General Information on Data Storage and Deletion”.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures, and services:
  • Contact form: When contacting us via our contact form, email, or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information, and, if applicable, further information communicated to us and necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Changes and Updates

We kindly ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g., consent) or any 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.

Definitions of Terms

In this section, you will find an overview of the terminology used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.
  • 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 details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems by enabling clear assignment and communication.
  • Content data: Content data includes information generated during the creation, editing, and publication of all types of content. 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 individuals or organizations. They include, among others, phone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
  • Meta, communication, and process data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information describing the context, origin, and structure of other data. It may include details on file size, creation date, document author, and revision histories. Communication data records the exchange of information between users across various channels, such as email traffic, call logs, social network messages, and chat histories, including the individuals involved, timestamps, and transmission paths. Process data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit logs used for tracking and verifying 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 showing how users utilize 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 frequency of use, activity timestamps, 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. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Log data: Log data are information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, 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 generating performance reports.
  • Controller: The “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, be it collection, evaluation, storage, transmission, or deletion.

Created with the free Privacy Policy Generator.de by Dr. Thomas Schwenke