This Privacy Policy informs you as to the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the "Online Offering"). With regard to the terminology used, e.g. "Processing" or "Controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR) of the European Union.
Controller
MICHAEL A. DUDLEY
Knausstraße 13
12157 Berlin
Germany
Types of Processed Data:
- Inventory data (e.g., names, addresses).
- Contact data (e.g., email addresses, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of Data Subjects:
Visitors and users of the online offering (hereinafter collectively referred to as "Users").
Purpose of Processing
- Provision of the online offering, its functions, and contents.
- Answering contact inquiries and communicating with users.
- Security measures.
- Audience measurement/marketing.
Terminology Used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as the "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 specific factors expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
"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.
"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing operations. If the legal basis is not specified in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR, the legal basis for processing for the performance of our services and execution of contractual measures as well as answering inquiries is Art. 6 (1) (b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 (1) (c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.
Security Measures
In accordance with Art. 32 GDPR, 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 risk of varying likelihood and severity for the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access concerning them, input, transfer, securing availability, and their separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. In addition, we take the protection of personal data into account during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).
Collaboration with Processors and Third Parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is required pursuant to Art. 6 (1) (b) GDPR for contract performance), you have consented, a legal obligation provides for it, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.). If we commission third parties to process data on the basis of a so-called "data processing agreement", this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosure or transmission of data to third parties, this only occurs if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. GDPR. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g., for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of Data Subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR. You have the right, in accordance with Art. 16 GDPR, to request the completion of data concerning you or the correction of inaccurate data concerning you. In accordance with Art. 17 GDPR, you have the right to request that data in question be deleted without undue delay, or alternatively, in accordance with Art. 18 GDPR, to request a restriction of the processing of the data. You have the right to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transmission to other controllers. Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.
Right of Withdrawal
You have the right to withdraw consents granted pursuant to Art. 7 (3) GDPR with effect for the future.
Right to Object
You may object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may be made in particular against processing for direct marketing purposes.
Cookies and Right to Object in Direct Marketing
"Cookies" are small files that are stored on users' computers. Various details can be stored within cookies. A cookie serves primarily to store information about a user (or the device on which the cookie is stored) during or even after their visit within an online offering. Temporary cookies, or "session cookies" or "transient cookies," are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. "Permanent" or "persistent" cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies offered by providers other than the controller operating the online offering (otherwise, if it is only their cookies, they are called "first-party cookies").
We may use temporary and permanent cookies and inform users about this within the scope of our privacy policy. If users do not want cookies stored on their computer, they are asked to disable the corresponding option in their browser's system settings. Saved cookies can be deleted in the browser's system settings. The exclusion of cookies can lead to functional restrictions of this online offering. A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by turning them off in the browser settings. Please note that not all functions of this online offering may be usable then.
Deletion of Data
The data processed by us are deleted or restricted in their processing in accordance with Arts. 17 and 18 GDPR. Unless expressly stated within this privacy policy, the data stored by us are deleted as soon as they are no longer required for their intended purpose and no statutory retention obligations prevent deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data are blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons.
According to legal requirements in Germany, storage is carried out in particular for 10 years pursuant to §§ 147 (1) AO, 257 (1) Nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to § 257 (1) Nos. 2 and 3, (4) HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years pursuant to § 132 (1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents related to electronically supplied services, telecommunication, broadcasting, and television services provided to non-entrepreneurs in EU member states for which the Mini One Stop Shop (MOSS) is used.
Business-Related Processing
Additionally, we process contract data (e.g., subject matter of contract, duration, customer category) and payment data (e.g., bank details, payment history) from our customers, interested parties, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.
Agency Services
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services. In doing so, we process inventory data (e.g., master customer data, such as names or addresses), contact data (e.g., email, phone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject matter of contract, duration), payment data (e.g., bank details, payment history), and usage and metadata (e.g., within the scope of evaluating and measuring the success of marketing measures). As a rule, we do not process special categories of personal data unless these are components of a commissioned processing. Data subjects include our customers, interested parties, as well as their customers, users, website visitors or employees, and third parties. The purpose of processing consists in the provision of contractual services, billing, and our customer service. The legal bases for processing result from Art. 6 (1) (b) GDPR (contractual services), and Art. 6 (1) (f) GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and fulfillment of contractual services and point out the necessity of their disclosure. Disclosure to external parties occurs only if it is necessary within the framework of an order. When processing data entrusted to us within the scope of an order, we act in accordance with the instructions of the clients and the legal requirements of commissioned processing pursuant to Art. 28 GDPR and process the data for no purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations; the necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years pursuant to § 257 (1) HGB, 10 years pursuant to § 147 (1) AO). In the case of data disclosed to us within the scope of an order by the client, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Contractual Services
We process the data of our contractual partners and interested parties as well as other clients, customers, patrons, or contractual partners (uniformly referred to as "Contractual Partners") in accordance with Art. 6 (1) (b) GDPR in order to provide our contractual or pre-contractual services to them. The data processed in this context, the nature, scope, purpose, and necessity of their processing are determined by the underlying contractual relationship.
The processed data include master data of our contractual partners (e.g., names and addresses), contact data (e.g., email addresses and telephone numbers), as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history). As a rule, we do not process special categories of personal data unless these are components of a commissioned or contract-compliant processing.
We process data that are necessary for the establishment and fulfillment of contractual services and point out the necessity of their disclosure if this is not evident to the contractual partners. Disclosure to external persons or companies occurs only if it is necessary within the framework of a contract. When processing data entrusted to us within the scope of an order, we act in accordance with the instructions of the clients and the legal requirements.
Within the scope of using our online services, we may store the IP address and the time of the respective user action. Storage is based on our legitimate interests as well as the interests of the users in protection against abuse and other unauthorized use. As a rule, these data are not passed on to third parties unless it is necessary for the prosecution of our claims pursuant to Art. 6 (1) (f) GDPR or there is a legal obligation to do so pursuant to Art. 6 (1) (c) GDPR.
The deletion of the data takes place when the data are no longer required for the fulfillment of contractual or statutory duty of care obligations and for dealing with any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise, the statutory retention obligations apply.
Use of Script Libraries (Google Web Fonts)
In order to display our contents correctly and graphically appealingly across all browsers, we use script and font libraries such as Google Web Fonts ( https://www.google.com/webfonts ) for this website. Google Web Fonts are transferred to your browser's cache so that they only need to be loaded once. If your browser does not support Google Web Fonts or denies access, contents are displayed in a standard font. When calling up script or font libraries, a connection to the provider of the library is automatically established. Theoretically, there is a possibility for this provider to collect data. It is currently unknown whether and for what purpose the providers of the corresponding libraries actually collect data. You can find the data protection provisions of the provider of the Google library here: https://www.google.com/policies/privacy .
Integration of YouTube Videos
We embed videos from the platform "YouTube", provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), on our website and/or in our newsletter. This integration is based on our legitimate interests in providing an appealing online presence (Art. 6 (1) (f) GDPR). As soon as you activate or play an embedded video, data is transmitted to Google servers and cookies are set. Further information on data processing by Google can be found in YouTube's privacy policy at: https://policies.google.com/privacy?hl=en
Integration of 3sat-Mediathek Content
We embed videos from the platform "3sat-Mediathek" on our website and/or in our newsletter. The entity responsible for data processing of this service is Zweites Deutsches Fernsehen (ZDF), a public law institution (ZDF-Straße 1, 55127 Mainz). This integration is based on our legitimate interests in providing an appealing online presence (Art. 6 (1) (f) GDPR). As soon as you activate or play an embedded video, data is transmitted to the broadcaster's servers. Further information on data processing can be found in the 3sat-Mediathek privacy policy at: https://www.3sat.de/datenschutz
Integration of Instagram Content
We embed content (such as videos or posts) from the platform "Instagram", provided by Meta Platforms Ireland Limited (Merrion Road, Dublin 4, D04 X2K5, Ireland), on our website and/or in our newsletter. This integration is based on our legitimate interests in providing an appealing online presence (Art. 6 (1) (f) GDPR). As soon as you activate or play an embedded element, data is transmitted to Meta servers and cookies are set. Further information on data processing by Meta can be found in Instagram's privacy policy at: https://privacycenter.instagram.com/
Advertising
When you access our website, we may serve advertisements using third-party ad technology. This technology uses your usage data of the services for ad delivery (e.g., by placing third-party cookies in your web browser).
You can opt out of numerous third-party ad networks, including networks operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). Information on how NAI and DAA members operate, your options regarding the use of such data by these companies, and how you can opt out of third-party ad networks operated by NAI and DAA members can be found on their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/ .
Minors
The protection of children's data is very important, especially in the online sphere. The website is not designed for or directed at children. The use of our services by minors is only permissible with the prior consent or authorization of a parent or legal guardian. We do not knowingly collect personal data from minors. If a parent or legal guardian becomes aware that their child has provided us with personal data without their consent, they can contact us at info@adverbismax.de.
Acknowledgment of Changes, Supplements, and Further Developments
We strive to keep our privacy policy up to date. Due to changes in applicable legislation, the evolution of new technologies, and the continuous development of this website, modifications may accordingly be made to this privacy policy. In light of this, we recommend that you reread the privacy policy at regular intervals and always use the most recent version of our privacy policy.
Last updated on: 11. October 2026