Privacy Policy

Preamble

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

The terms used are not gender-specific.

Last updated: July 14, 2026

Table of Contents

• Preamble
• Controller
• Overview of Processing Activities
• Applicable Legal Bases
• Security Measures
• Transmission of Personal Data
• International Data Transfers
• General Information on Data Storage and Deletion
• Rights of Data Subjects
• Provision of the Online Offering and Web Hosting
• Use of Cookies
• Blogs and Publication Media
• Contact and Inquiry Management
• Changes and Updates
• Definitions of Terms

Controller

First Name, Last Name / Company Street, House No. Postal Code, City, Country Email: contact@sentiniq.de

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 affected.

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

• Service recipients and clients.
• Employees.
• Communication partners.
• Users.
• Third parties.
• Whistleblowers.

Purposes of processing

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

Applicable Legal Bases

Applicable legal bases under the GDPR: Below is 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 in your or our country of residence or registered office may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6(1) sentence 1 (a) GDPR) – The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 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) sentence 1 (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6(1) sentence 1 (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, fundamental rights, and fundamental freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the GDPR's data protection provisions, national regulations on data protection apply in Germany. This includes, in particular, the Act to Adapt Data Protection Law to Regulation (EU) 2016/679 and to Implement Directive (EU) 2016/680 (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions on 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.

Note on the applicability of the GDPR and the Swiss FADP: These privacy notices serve to provide information under both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that, due to the broader territorial scope and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss FADP such as "processing" of "personal data," "overriding interest," and "particularly sensitive personal data," the terms used in the GDPR, namely "processing" of "personal data" as well as "legitimate interest" and "special categories of data," are used. However, the legal meaning of the terms will continue to be determined under the Swiss FADP within the scope of its applicability.

Applicability of data protection provisions in the country of registered office: In the country where the controller has its registered office, national data protection provisions apply in addition to the General Data Protection Regulation (GDPR).

Security Measures

In accordance with legal requirements, and taking into account the state of the art, the costs of implementation, and 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 take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These 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 it, its entry, transfer, ensuring its availability, and its separation. In addition, we have established procedures to ensure that data subjects can exercise their rights, that data is deleted, and that we can respond to any threats to the data. Furthermore, we take the protection of personal data into account from the outset when developing or selecting hardware, software, and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Securing online connections via TLS/SSL encryption technology (HTTPS): To protect user data transmitted through 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 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 more advanced and 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 indicated 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 occur that such data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, service providers entrusted with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of 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 connection with the use of third-party services or the disclosure or transmission of data to other persons, bodies, or companies (which becomes apparent from the postal address of the respective provider, or when the privacy policy expressly refers to the transfer of data to third countries), this is always done in accordance 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 dated July 10, 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the EU Commission's requirements and establish contractual obligations to protect your data.

This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as an additional safeguard. Should changes occur within the framework of the DPF, the standard contractual clauses take effect as a reliable fallback option. This ensures 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 U.S. Department of Commerce at https://www.dataprivacyframework.gov/ (in English).

For data transfers to other third countries, corresponding safeguards apply, in particular standard contractual clauses, explicit consent, or transfers required by law. Information on third-country transfers and applicable adequacy decisions can be found on the EU Commission's information page: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is revoked or no other legal grounds for processing exist. This applies to cases in which the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply 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 the pursuit of legal claims 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 applies specifically to certain processing operations.

Where multiple retention periods or deletion deadlines are specified for a given piece of data, the longest period shall always apply. Data that is no longer retained for its originally intended purpose, but rather due to legal requirements or other reasons, is processed exclusively for the reasons justifying its retention.

Start of retention period at the end of the year: Unless a period expressly begins 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 point in time at which the termination or other ending of the legal relationship becomes effective.

Rights of Data Subjects

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

• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is 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 your personal data for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw any consent given at any time.
• Right of access: You have the right to request confirmation as to whether the data concerned is being processed, and to request access to this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with legal requirements, to demand a restriction on the processing of the data.
• Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with legal requirements, in a structured, commonly used, and machine-readable format, or to request 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 violates the requirements of the GDPR.

Provision of the Online Offering and Web Hosting

We process user data in order to provide our online services to them. For this purpose, we process the user's IP address, which is necessary to deliver the content and functions of our online services to the user's browser or terminal device.

Types of data processed: Usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved); log data (e.g., log files relating to logins or data retrieval or access times).

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 such as computers, servers, etc.); security measures.

Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Storage and Deletion."

Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR).

Additional notes on processing activities, procedures, and services:

• Provision of the 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 an appropriate server provider (also referred to as a "web host"); Legal bases: Legitimate interests (Art. 6(1) sentence 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 web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and, on the other hand, to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR). Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is excluded from deletion until the incident in question has been finally clarified.

Use of Cookies

The term "cookies" refers to functions that store and read information on users' terminal devices. Cookies may also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as generating analyses of visitor flows. We use cookies in accordance with legal requirements. Where necessary, we obtain users' prior consent. Where consent is not required, we rely on our legitimate interests. This applies where the storage and reading of information is essential in order to provide expressly requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent may be withdrawn at any time. We provide clear information about the scope of consent and which cookies are used.

Notes on legal bases under data protection law: Whether we process personal data using cookies depends on consent. Where consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, as explained above in this section and in the context of the respective services and procedures.

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

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

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

Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).

Data subjects: Users (e.g., website visitors, users of online services).

Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR); consent (Art. 6(1) sentence 1 (a) GDPR).

Additional notes on processing activities, procedures, and services:

• Processing of cookie data based on consent: We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers named within the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consents, in particular relating to the use of cookies and comparable technologies used to store, read, and process information on users' terminal devices. As part of this procedure, users' consent for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure, is obtained. Users also have the option to manage and withdraw their consent. Consent declarations are stored in order to avoid repeated queries 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 using comparable technologies, in order to be able to assign the consent to a specific user or their device. Unless specific information is provided regarding consent management service providers, the following general information applies: the consent is stored for up to two years. In doing so, a pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., the relevant categories of cookies and/or service providers), and information about the browser, system, and terminal device used; Legal bases: Consent (Art. 6(1) sentence 1 (a) GDPR).

Blogs and Publication Media

We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers, or for security reasons. Otherwise, we refer to the information on the processing of visitors to our publication medium provided elsewhere in these privacy notices.

Types of data processed: Inventory data (e.g., full name, home 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 posts, as well as information relating to them, such as details on authorship or the time of creation); usage data (e.g., page views and duration of visits, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, persons involved).

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing and legitimate interests: Feedback (e.g., collecting feedback via online form); provision of our online offering and user-friendliness; security measures; organizational and administrative procedures.

Retention and deletion: Deletion in accordance with the information provided in the section "General Information on Data Storage and Deletion."

Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR).

Additional notes on processing activities, procedures, and services:

• Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our own security, in case someone leaves unlawful content in comments or posts (insults, prohibited political propaganda, etc.). In such cases, we may ourselves be held liable for the comment or post and are therefore interested in the identity of the author.
  Furthermore, we reserve the right to process user information for the purpose of spam detection on the basis of our legitimate interests.
  On the same legal basis, we also reserve the right, in the case of surveys, to store users' IP addresses for the duration of the survey and to use cookies to prevent multiple votes.
  Information provided by users in connection with comments and posts regarding their personal details, any contact and website information, as well as the content itself, will be stored by us permanently until the user objects; Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by mail, contact form, email, telephone, or via social media), as well as within the context of existing user and business relationships, the information provided by the inquiring parties is processed to the extent necessary to respond to the 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 posts, as well as information relating to them, such as details on authorship or the time of creation); meta, communication, and procedural data (e.g., IP addresses, timestamps, 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 deletion: Deletion in accordance with the information provided in the section "General Information on Data Storage and Deletion."

Legal bases: Legitimate interests (Art. 6(1) sentence 1 (f) GDPR); performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 (b) GDPR).

Additional notes on processing activities, procedures, and services:

• Contact form: When contacting us via our contact form, by email, or through other means of communication, we process the personal data transmitted to us in order to respond to and process the respective inquiry. This generally includes information such as name, contact details, and any additional information provided to us that is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 (b) GDPR), legitimate interests (Art. 6(1) sentence 1 (f) GDPR).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy whenever changes to the data processing we carry out make this necessary. We will inform you as soon as such changes require your cooperation (e.g., consent) or any other individual notification.

Where we provide addresses and contact information of companies and organizations in this privacy policy, please note that such addresses may change over time, and we ask that you verify the details before making contact.

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. Where terms are defined by law, their legal definitions apply. The explanations below are intended primarily to aid understanding.

Employees: Employees are persons who are in an employment relationship, whether as staff, salaried 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 encompasses various phases, including its establishment, in which the employment contract is concluded; its performance, during which the employee carries out their work; and its termination, when the employment relationship ends, whether through 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 banking details, working hours, vacation entitlements, health data, and performance appraisals.

Inventory data: Inventory data comprises essential information necessary for identifying and managing 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 individuals and services, facilities, or systems by enabling clear identification and communication.

Content data: Content data comprises information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.

Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, 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 manner in which data is processed, transmitted, and managed. Metadata, also known as data about data, comprises information that describes the context, origin, and structure of other data. It may include details on file size, creation date, the author of a document, and revision histories. Communication data records the exchange of information between users through various channels, such as email traffic, call logs, messages in social networks, and chat histories, including the persons involved, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review 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 use applications, which functions they prefer, how long they spend on certain pages, and the paths they take through an application. Usage data may also include the frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, 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., a 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 is information about events or activities recorded 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 issues, security monitoring, or generating performance reports.

Controller: The "controller" refers to 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 virtually any handling of data, whether collecting, evaluating, storing, transmitting, or deleting it.