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Data protection

I. General information on data protection

Note on the responsible body:

Living Bytes Kundenbindungs- und Kundengewinnungsprogramme GmbH
Holsteiner Chaussee 183a
22457 Hamburg
E-Mail privacy[at]touchincentive.de

We attach particular importance to the protection of your personal data. Your personal data will be processed in accordance with data protection regulations, in particular the European General Data Protection Regulation (GDPR).

The following information provides an overview of the nature, scope and purpose of the collection, processing and transfer of personal data, as well as the security measures used to protect this data.

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Legal basis for the processing of personal data

  • Insofar as we obtain the consent of the data subject for the processing of personal data, Article 6(1)(a) GDPR serves as the legal basis. You may revoke this consent at any time in accordance with Article 7(3) GDPR for the future.
  • When processing personal data that is necessary for the performance of a contract or for the implementation of pre-contractual measures, Article 6(1)(b) GDPR serves as the legal basis.
  • Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.
  • If processing is necessary to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh this, Art. 6(1)(f) GDPR serves as the legal basis for processing. In this case, you have a right to object under Art. 21 GDPR.

Data deletion and storage period

Personal data will be deleted as soon as the purpose for storage no longer applies. Storage may also take place if this is provided for by statutory retention obligations to which our company is subject (e.g. accounting or tax retention periods of up to 10 years in accordance with the German Fiscal Code (AO) and the German Commercial Code (HGB)).

Your rights

Upon request, we will inform you in accordance with Art. 15 GDPR and in accordance with our legal obligation under Art. 12 GDPR whether and which personal data we process or store about you. Furthermore, you have the right to rectification of inaccurate data in accordance with Art. 16 GDPR, data portability in accordance with Art. 20 GDPR, blocking and erasure of your personal data in accordance with Art. 17 GDPR – provided that there are no legal retention obligations to the contrary – as well as the right to restriction of processing in accordance with Art. 18 GDPR. In addition, you have the right to contact the competent supervisory authority in accordance with Art. 77 GDPR.

IN ADDITION, YOU HAVE THE RIGHT TO OBJECT IN ACCORDANCE WITH ART. 21 GDPR, INSOFAR AS THE PROCESSING IS BASED ON THE LEGITIMATE INTERESTS IN ACCORDANCE WITH ART. 6 PAR. 1 LIT. F GDPR.

If you have given us your consent to process your data, you can of course revoke this consent at any time in accordance with Art. 7(3) GDPR.

If you have any questions regarding the processing of your personal data, you can contact our data protection officer, who is also available to assist you with any requests for information, suggestions or complaints.

Data protection officer
Living Bytes Kundenbindungs- und Kundengewinnungsprogramme GmbH
Holsteiner Chaussee 183a
22457 Hamburg
E-Mail: privacy[at]touchincentive.de

Changes to our privacy policy

In order to ensure that our privacy policy always complies with current legal requirements, we reserve the right to make changes at any time. This also applies in the event that the privacy policy needs to be adapted due to new or revised services, for example new services.

As of 2025

II. Website privacy policy

Provision of the website

Use of hosting service providers

Our website is hosted on servers located in the EU by a hosting service provider on the basis of order processing in accordance with Art. 28 GDPR. The hosting service provider may have access to our users' personal data as part of its services, in particular to technical data that arises in the course of technical communication between you and our website (e.g. server log files). It may not use this data for its own purposes. The use of a hosting service provider is based on our legitimate interests pursuant to Art. 6(1)(f) GDPR in the provision of infrastructure and platform services, computing capacity, email delivery and security services.

Server-Logfiles

When you visit our website or use its services, the device you use to access the site automatically transmits log data (connection data) to our server. The relevant information consists of:

  • Type and version of the browser you are using,
  • Type and version of the operating system you are using,
  • Referrer URL of the page from which you accessed our website,
  • Date and time of your visit to our website,
  • Name of the subpages you accessed,
  • IP address of your computer system,
  • Amount of data transferred in each case.

The data collected is used exclusively for statistical evaluations for the purpose of operating, securing and optimising the website. For security reasons, however, we reserve the right to subsequently review the log data if there are concrete indications of justified suspicion of illegal use. The data will not be stored for longer than necessary for this purpose. This collection is based on our legitimate interests pursuant to Art. 6(1)(f) GDPR.

Cookies

We use cookies in some areas of the website to recognise visitors' preferences and to optimise the design of the website accordingly. This facilitates navigation and ensures a high level of user-friendliness for the website. The processing of cookies for the technical provision of the website constitutes a legitimate interest pursuant to Art. 6 (1) lit. f GDPR / § 25 (2) TDDDG. In addition, the legal basis is Art. 6 (1) (a) GDPR or § 25 (1) TDDDG, insofar as we require your consent for the use of cookies (e.g. for marketing or analysis purposes).

Cookies are technologies that your browser automatically creates and that are stored on your device when you visit our website. Cookies do not cause any damage to your computer and do not contain viruses. Most of the cookies we use are deleted after the end of the browser session (so-called session cookies). Other cookies remain on your computer and enable us to recognise your computer the next time you visit (known as permanent or cross-session cookies). Thanks to these files, it is possible, for example, to display information on the page that is specifically tailored to your interests.

You can set your browser to notify you when cookies are placed. This makes the use of cookies transparent for you. If you completely exclude the use of cookies, you may not be able to use certain functions of this website.

Security of your data

We use technical and organisational security measures to adequately protect the data you provide from accidental or intentional manipulation, loss, destruction or access by unauthorised persons. We therefore use SSL encryption for the transmission of confidential content, such as enquiries you send to us as the website operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL encryption is activated, the data you transmit to us cannot be read by third parties. Our security measures are continuously developed in line with the latest technology.

Contact

If you contact us (e.g. via contact form, e-mail, telephone, social media), your personal details will be processed for the purpose of processing your enquiry and any follow-up questions in accordance with Art. 6(1)( telephone, social media), your personal data will be stored and processed by us for the purpose of processing your enquiry and any follow-up questions in accordance with Art. 6 (1) (b) GDPR (within the framework of pre-contractual measures) or in accordance with Art. 6 (1) (f) GDPR (general enquiries). We will not pass on this data without your consent.

The data you provide will remain with us until you request us to delete it, object to its storage or the purpose for data storage no longer applies (i.e. after your enquiry has been processed), provided that there are no legal retention obligations to the contrary.

Registration

When you register on our website to order goods, services and information from our online portal, personal data is collected. Registration allows you to access services and content that are only available to registered users. If necessary, registered users can change or delete the data provided during registration at any time. Your data may be passed on to shipping and payment service providers commissioned by us for the purpose of processing the order. No further transfer to third parties takes place. The processing of your personal data is carried out on the basis of contract processing (in accordance with Art. 6 (1) (b) GDPR). This data is deleted in accordance with the statutory retention obligations.

Google Analytics

This website uses functions of the web analysis service Google Analytics to measure and analyse usage behaviour on our website and to improve our online offering and tailor it to the needs of our users. The provider of the service is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Pseudonymous profiles based on the use of different devices may be created for the purpose of analysing and better tracking user behaviour. Google Analytics uses cookies for this purpose. These cookies enable us to track a user's behaviour on different devices without identifying a specific person. The use of Google Analytics is based on your consent in accordance with Art. 6 (1) (a) GDPR. The data collected is stored for 14 months before being automatically deleted.

Geolocation and IP anonymisation
Google Analytics does not use individual IP addresses in the EU. Instead, rough geographical location data is stored based on the following derived information: city (as well as the city's latitude and longitude), continent, country, region, subcontinent (and associated ID-based counterparts). For EU users, the IP address is used exclusively for geolocation and is then immediately deleted. The full IP address is not stored, logged or used for any other purpose. All IP queries are performed on servers within the EU before the data is forwarded to Google Analytics servers for further processing. The data collected by Google Analytics may be processed on Google servers in the United States. Google LLC is certified under the Data Privacy Framework and is committed to ensuring an adequate level of data protection. In addition, a data processing agreement has been concluded with Google, which can be accessed here: https://business.safety.google/adsprocessorterms/

Withdrawal of consent and opt-out options
You may withdraw your consent to data processing by Google Analytics at any time. You can do this either by adjusting your cookie settings on our website or by installing the Google Analytics opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de. Alternatively, you can prevent the storage of cookies by adjusting your browser software settings accordingly. Please note, however, that this may restrict the use of certain functions of our website.

For more information on how Google handles user data, please refer to Google's privacy policy: https://policies.google.com/privacy.

Third-party content and services

Based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR, content, services and offerings from other providers that complement our offering are integrated into our online offering. By using the services listed below, we aim to ensure that our website is designed to meet your needs and is continuously optimised. If we ask for your consent to use these services, the legal basis is Article 6(1)(a) of the GDPR.

Google Tag Manager

Google Tag Manager is used on our website. Google Tag Manager (GTM) is a solution from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which allows us to manage website tags via an interface. GTM itself (which implements the tags) is a tool that does not create user profiles, does not store cookies with user profiles and does not perform any independent analyses. Its function is limited to the integration and management of tools and services that we use on our website. Nevertheless, when using Google Tag Manager, the IP address of website visitors is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. The use of GTM is based on our legitimate interest pursuant to Art. 6 (1) lit. f GDPR in the quick and uncomplicated integration and management of various tools on our website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR. The tags/services used are listed separately in this privacy policy and can be edited individually in the privacy settings, for example by deactivating cookies for these elements. Further information can be found at: https://www.google.com/policies/privacy/.

YouTube

Videos from the YouTube platform are embedded on our website. YouTube is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The videos are embedded on our website in extended data protection mode. The domain is replaced by the official YouTube no-cookie domain. When using this variant, information about visitors to the website is only stored when the video is played. Like most websites, YouTube also uses cookies to collect information about visitors to its website. YouTube uses these cookies to collect video statistics, prevent fraud and improve user-friendliness, among other things.

Further information on data protection at YouTube can be found in their privacy policy at: http://www.youtube.com/t/privacy_at_youtube. There you will also find further information on your rights and settings options for protecting your privacy.

Links to third-party websites

Based on our legitimate interest, links to other providers that supplement our offering may be included within this online offering. When you visit websites referred to on this website, you may be asked again for information such as your name, IP address, browser properties, etc. This privacy policy does not regulate the collection, disclosure or handling of personal data by third parties. In this context, please note the specific privacy policies of the individual third-party providers and service providers whose links we include on our website.

Social Media

We maintain publicly accessible online presences on social networks to communicate with customers and interested parties who are active there and to showcase our services.

We would like to point out that user data may be processed outside the European Union. Furthermore, user data is generally processed for market research and advertising purposes. To the best of our knowledge, providers also use cookies that store your usage behaviour (even across different devices). This allows targeted advertising to be displayed on their own platform and on third-party websites.

The processing of users' personal data is based on our legitimate interests in effectively informing users and communicating with them in accordance with Art. 6(1)(f) GDPR. If users are asked by the respective providers of the platforms for consent to data processing or if information is sent voluntarily by the user to our online presences, the legal basis for processing is Art. 6 para. 1 lit. a GDPR in conjunction with Art. 7 GDPR. If this information contains contract-related content, Art. 6 (1) lit. b GDPR serves as the legal basis.

For a detailed description of the respective processing and the options for objection (opt-out), please refer to the information provided by the providers linked below.

In the case of requests for information and the assertion of user rights, we would like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. However, if you still require assistance, you can contact us.

Facebook und Instagram (Meta)

When you interact with our social media pages on Facebook and Instagram (by commenting, liking posts or sending us a message), your data is stored by us. These social networks are operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (hereinafter: Meta).

When operating a company profile on these channels, Meta and our company share responsibility under data protection law in accordance with Art. 26 GDPR. Accordingly, we have entered into an agreement with Meta that regulates the respective obligations under the GDPR: https://www.facebook.com/legal/terms/page_controller_addendum.

Meta provides profile operators with statistics and insights into the types of actions taken by visitors to our profiles ("Page Insights"). We have no influence over the collection of this data by Meta. According to Meta, this data is provided to us in anonymised form only, meaning that users cannot be identified from the information.

Personal data will be deleted as soon as the purpose for storing it no longer applies. Data may also be stored beyond this period if this is required by statutory retention obligations to which our company is subject.

Please note that when you use and visit our Facebook and Instagram pages, your personal data will also be processed by Meta. Meta is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, and its parent company based in the United States. In addition to the processing mentioned above, Meta processes your data for analysis and advertising purposes. To the best of our knowledge, Meta also uses cookies that store your usage behaviour (even across different devices). This enables Meta to display targeted advertising on its own platform and on third-party sites. Further information can be found in Facebook's privacy policy: https://www.facebook.com/about/privacy/ , Instagram https://help.instagram.com/519522125107875. Facebook and Instagram also offer the option to object to certain data processing; information on this and opt-out options can be found at: https://www.facebook.com/settings?tab=ads and https://www.instagram.com/accounts/privacy_and_security/. Please note that, in accordance with Meta's privacy policy, user data may also be processed in the USA or other third countries. Meta only transfers user data to countries for which the European Commission has issued an adequacy decision in accordance with Art. 45 GDPR or on the basis of appropriate safeguards in accordance with Art. 46 GDPR.

With regard to data processing via our Facebook and Instagram pages, you also have the option of asserting your rights as a data subject against Meta. Further information on this can be found in Meta's privacy policy: https://www.facebook.com/about/privacy/.

Minors

Our online offering is generally aimed at adults. Personal information relating to persons under the age of 16 may only be provided to us with the express consent of their legal guardian (Art. 8 GDPR). Processing without the consent of the legal guardian is not permitted. We therefore reserve the right to delete all data relating to minors unless we have obtained the consent of a parent or legal guardian.

III. Information for applicants

Purpose and legal basis for collection and processing

Your data will be processed by us for the purpose of application processing in accordance with Art. 6 (1) lit. c GDPR in conjunction with § 26 BDSG. If special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily provided during the application process, they will also be processed in accordance with Art. 9 (2) lit. b GDPR.

Recipients of your data

The recipients of your data are the departments involved in the human resources process (including human resources, managers and department heads) of the responsible body. Your data will be treated as strictly confidential and will not be passed on to third parties without your consent. There are no plans to transfer your data to third countries or international organisations.

Storage of your data

Your application data will be deleted 180 days after the position has been filled. If you are also interested in future vacancies, we require your written consent to store your application documents for a longer period of time. You can revoke this consent at any time in accordance with Art. 7 (3) GDPR. To do so, please send an email with the relevant information to the contact address above.

IV. Information for business partners

Purpose and legal basis for collection and processing

Data processing primarily serves to establish, execute and terminate the contractual relationship. The primary legal basis for this is Art. 6(1)(b) GDPR. Without this type of use of your data, it is not possible to execute the business relationship between you and us.

We also process your data on the basis of Art. 6 (1) lit. f GDPR to protect our legitimate interests or those of third parties (e.g. authorities). This may be necessary, for example, to maintain IT security and IT operations or for the purposes of corporate management, internal communication and other administrative purposes. You may object to this processing on specific grounds pursuant to Art. 21 GDPR.

We also process your data to fulfil legal obligations, such as regulatory requirements, commercial and tax retention obligations, or documentation obligations. The legal basis for this is Article 6(1)(c) GDPR in conjunction with the applicable national laws.

In individual cases, we may also process your data on the basis of your separate consent in accordance with Articles 6(1)(a) and 7 GDPR (e.g. when you subscribe to our newsletter or publish photos and videos). You are always free to decide whether you wish to give your consent. Once you have given your consent, you can revoke it at any time with effect for the future. To do so, please use the link provided in the respective action or send a request to the contact address above.

Should we process your personal data for a purpose not mentioned above, we will inform you in advance.

Recipients of your data

Within our company, only those persons who need your personal data to fulfil our contractual and legal obligations will receive it. In addition, we use various service providers to fulfil these obligations, which may require us to transfer your personal data to other recipients outside the company, insofar as this is necessary to fulfil our contractual and legal obligations. These third parties may include authorities, financial institutions, suppliers, etc.

We sometimes use external service providers to process your data technically. We may transfer and process your data outside the country in which you reside or have your registered office, or in one of the countries in which we operate. These countries may also be located outside the European Economic Area. If we transfer personal data to service providers or companies outside the European Economic Area (EEA), the transfer will only take place if the third country has been confirmed by the EU Commission as having an adequate level of data protection or if other appropriate data protection guarantees (e.g. binding internal company data protection regulations or EU standard contractual clauses) are in place. You can also request detailed information using the contact details above.

Storage of your data

We only store your personal data for as long as it is necessary for the above-mentioned purposes. After termination of the contractual relationship, your personal data will be stored for as long as we are legally obliged to do so. This regularly results from legal obligations to provide evidence and retain data, which are regulated in the German Commercial Code and the German Fiscal Code, among others. The storage periods are up to ten years. In addition, personal data may be retained for the period during which claims can be asserted against us (statutory limitation period of three or up to thirty years).

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