The controller pursuant to Art. 4 (7) EU General Data Protection Regulation (GDPR) is lowcloud UG (haftungsbeschränkt) i.G., Obernstraße 50, 33602 Bielefeld, Germany, Email: support@lowcloud.de.

We detail the scope of data processing, purposes of processing, and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

• Art. 6 (1) sentence 1 lit. a GDPR serves as our legal basis for processing operations for which we obtain consent.
• Art. 6 (1) sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. when a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing operations that are necessary for pre-contractual measures, such as inquiries about our products or services.
• Art. 6 (1) sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.
• Art. 6 (1) sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests for the processing of personal data, e.g. for cookies that are necessary for the technical operation of our website.

Insofar as we transmit data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 (3) GDPR guarantee the security of the data during transfer, insofar as these exist, as is the case for Great Britain, Canada, and Israel, for example. In the case of data transfer to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has additionally certified itself under the EU US Data Privacy Framework. In other cases (e.g. if no adequacy decision exists), the legal basis for the data transfer is generally, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and part of the contract with the respective third party. According to Art. 46 (2) lit. b GDPR, they guarantee the security of the data transfer. Many of the providers have provided contractual guarantees that go beyond the standard contractual clauses to protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of data or regarding an obligation of the third party to notify data subjects if law enforcement authorities want to access data.

Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax reasons.

Data subjects have the following rights against us regarding personal data concerning them:

• Right to information,
• Right to rectification or deletion,
• Right to restriction of processing,
• Right to object to processing,
• Right to data portability,
• Right to withdraw consent given at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

Customers, interested parties, or third parties must only provide us with those personal data within the framework of a business relationship or other relationship that are necessary for the establishment, execution, and termination of the business relationship or for the other relationship or which we are legally obliged to collect. Without this data, we will generally have to refuse the conclusion of a contract or the provision of a service or will no longer be able to carry out an existing contract or other relationship. Mandatory information is marked as such.

For the establishment and execution of a business relationship or other relationship, we generally do not use fully automated decision-making pursuant to Article 22 GDPR. Should we use these procedures in individual cases, we will inform you about this separately if this is required by law.

When contacting us, e.g. by email or telephone, the data provided to us (e.g. names and email addresses) will be stored by us to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 (1) sentence 1 lit. f GDPR) to answer inquiries directed to us. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 (1) sentence 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

We reserve the right to inform customers who have already used our services or purchased goods from time to time by email or other means about our offers, provided they have not objected to this. The legal basis for this data processing is Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without additional costs, for example via the link at the end of each email or by email to our email address mentioned above. Based on the consent of the recipients (Art. 6 (1) sentence 1 lit. a GDPR), we also measure the opening and click rate of our newsletters to understand which content is relevant to our recipients. We send newsletters with Brevo. The provider processes content, usage, meta/communication data, and contact data.

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). Which information this is in detail can be found in the following sections. This storage and access takes place on the basis of the following provisions:

• Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g. to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it takes place on the basis of § 25 (2) No. 2 of the Telecommunications-Digital-Services-Data-Protection-Act (TDDDG).
• Otherwise, this storage or access takes place on the basis of the consent of the website visitors (§ 25 (1) TDDDG).

The downstream data processing takes place in accordance with the following sections and on the basis of the provisions of the GDPR.

In the case of informational use of the website, i.e. if site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 (1) sentence 1 lit. f GDPR. These data are:

• IP address
• Date and time of the request
• Time zone difference to Greenwich Mean Time (GMT)
• Content of the request (concrete page)
• Access status/HTTP status code
• Amount of data transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software.

These data are also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

Our website is hosted by Hetzner. The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data, or contact data, in the EU. Further information can be found in the provider's privacy policy at https://www.hetzner.de/datenschutz/. It is our legitimate interest to provide a website, so that the legal basis for the described data processing is Art. 6 (1) sentence 1 lit. f GDPR. We have a legitimate interest in using sufficient storage and delivery capacities to ensure optimal data throughput even during large load peaks. The legal basis for the described data processing is therefore Art. 6 (1) sentence 1 lit. f GDPR. The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided within the framework of an adequacy decision pursuant to Art. 45 (3) GDPR that the third country offers an adequate level of protection.

When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for the processing is our legitimate interest to answer inquiries directed to us. The legal basis for the processing is therefore Art. 6 (1) sentence 1 lit. f GDPR. We delete the data arising in this context after storage is no longer necessary, or restrict processing if statutory retention obligations exist.

We publish job advertisements on our website, on pages connected to the website, or on third-party websites. The processing of the data provided in the context of the application takes place for the purpose of carrying out the application process. Insofar as these are necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) GDPR in conjunction with § 26 (1) BDSG. We have marked the data required for carrying out the application process accordingly or point them out. If applicants do not provide this data, we cannot process the application.

Further data are voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6 (1) sentence 1 lit. a GDPR). We ask applicants to refrain from providing information on political opinions, religious beliefs, and similarly sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing in the context of processing the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 (2) lit. a GDPR).

Finally, we process the data of applicants for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 (1) sentence 1 lit. a GDPR. We pass on the data of applicants to the responsible employees of the HR department, to our processors in the field of recruiting, and to the employees otherwise involved in the application process. If we enter into an employment relationship with the applicant following the application process, we only delete the data after the termination of the employment relationship. Otherwise, we delete the data at the latest six months after rejection of an applicant. If applicants have given us their consent to use their data for further application procedures as well, we delete their data only one year after receipt of the application.

Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of the consent of the site visitor. The legal basis for the processing is therefore Art. 6 (1) sentence 1 lit. a GDPR. The consent can be withdrawn at any time, e.g. via the contact details given in our privacy policy. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. If consent is withdrawn, we delete the data unless we are obliged or entitled to retain it further.

Our website uses cookies. Cookies are small text files that are stored in the web browser on the terminal device of a site visitor. Cookies help to make the offer more user-friendly, effective, and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “Technically necessary cookies”), the legal basis for the associated data processing is Art. 6 (1) sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.

Specifically, we use technically necessary cookies for the following purpose or purposes:

• Cookies that adopt language settings,
• Cookies that remember search terms,
• Cookies that store log-in data and
• Flash cookies that are set for the playback of media content

We use the analysis service PostHog to analyze user behavior and for product optimization. The provider is PostHog, Inc., 2261 Market Street Suite 4008, San Francisco, California, 94114, United States.

The provider processes usage data (e.g. visited websites, clicks, interest in content, access times) and meta/communication data (e.g. device information, IP addresses for geolocation) in the USA.

The legal basis for the processing is Art. 6 (1) sentence 1 lit. a GDPR. The processing takes place on the basis of consent. Data subjects can withdraw their consent at any time by contacting us, e.g. under the contact details given in our privacy policy. The withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

The transfer of personal data to a country outside the EEA takes place on the legal basis of an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided within the framework of an adequacy decision pursuant to Art. 45 (3) GDPR that the third country (USA) offers an adequate level of protection (EU-US Data Privacy Framework).

The data will be deleted when the purpose of their collection no longer applies and no retention obligation conflicts. Further information can be found in the provider's privacy policy at https://posthog.com/privacy

We are represented in social media networks to present our organization and our services there. The operators of these networks regularly process data of their users for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the operators of the networks store information on user behavior in cookies on the user's computer. Furthermore, it cannot be ruled out that the operators merge this information with other data. Further information and notes on how users can object to the processing by the site operators can be found in the privacy policies of the respective operators listed below. It may also be that the operators or their servers are located in non-EU countries, so that they process data there. This can result in risks for users, e.g. because the enforcement of their rights is made more difficult or state authorities access the data. If users of the networks contact us via our profiles, we process the data provided to us to answer the inquiries. This is our legitimate interest, so the legal basis is Art. 6 (1) sentence 1 lit. f GDPR.

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. A possibility to object to data processing can be found in the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

We reserve the right to change this privacy policy with effect for the future. A current version is available here in each case.

For questions or comments regarding this privacy policy, we are happy to be at your disposal under the contact details given above.