PRIVACY POLICY

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 as ‘data’) that we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offer’).
The terms used are not gender-specific.
Last updated: 21 June 2025

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Table of contents
• Preamble
• Data controller
• Overview of processing
• Relevant legal bases
• Security measures
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Provision of the online offer and web hosting
• Use of cookies
• Contact and request management
• Plug-ins and embedded functions and content
• Changes and updates
• Definitions of terms

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Data controller
WE CONCEPT SPAIN SL
Calle Jose Tous Ferrer 8
Piso 2
07002 Palma de Mallorca
Islas Baleares
Spain
Email address: box@weconcept.eu

Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
• Inventory data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication and process data.
• Protocol data.

Categories of data subjects
• Communication partners.
– Users.

Purposes of processing
• Communication.
• Security measures.
• Organisational and administrative procedures.
• Feedback.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.

Relevant legal bases
Relevant legal bases under the GDPR (General Data Protection Regulation): Below you will find an overview of the GDPR legal bases under which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the Privacy Policy.

• Consent (Art. 6(1)(1)(a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.

• Contract fulfilment and pre-contractual requests (Art. 6(1)(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.

• Legitimate interests (Art. 6(1)(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations in Germany apply. This includes, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations 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 transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The 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, input, transfer, safeguarding of availability and separation concerning that data. We have also set up procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised 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 that is transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorised access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, HTTPS will be displayed in the URL. This serves as an indicator to users that their data is transmitted securely and encrypted.

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 happens in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies (which can be identified by the postal address of the respective provider or if the data protection declaration expressly refers to the transfer of data to third countries), this is always done in accordance with the legal requirements.

For data transfers to the United States, we rely primarily on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission on 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and stipulate contractual obligations to protect your data.

This dual protection guarantees the comprehensive protection of your data: The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes occur within the framework of the DPF, the standard contractual clauses act as a reliable fall-back option. In this way, we ensure that your data always remains appropriately protected, even in the event of any political or legal changes.

For the individual service providers, we will inform you whether they are certified in accordance with the DPF and whether standard contractual clauses exist. Further information on the DPF and a list of certified companies can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/.

Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or legally required transfers. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=en.

General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This concerns cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.

In particular, data that must be stored for commercial or tax law reasons or whose retention is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there is more than one indication of the retention period or deletion period for a piece of data, the longest period is always decisive. We only process data that is no longer retained for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its retention.

Retention and deletion of data: The following general time limits apply to retention and archiving in accordance with German law:

• 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet and the work instructions and other organisational documents required to understand them (§ 147(1)(1) in conjunction with (3) AO (German Fiscal Code), § 14b(1) UStG (VAT Act), § 257(1)(1) in conjunction with (4) HGB (German Commercial Code)).

• 8 years – Accounting documents, such as invoices and expense receipts (§ 147(1)(4) and (4a) in conjunction with (3)(1) AO and § 257(1)(4) in conjunction with (4) HGB).

• 6 years – Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents, insofar as they are of significance for taxation, e.g. time sheets, company accounting sheets, calculation documents, price labelling, but also payroll accounting documents, insofar as they are not already accounting documents and till slips (§ 147(1)(2), (3), (5) in conjunction with (3) AO), § 257(1)(2) and (3) in conjunction with (4) HGB).

• 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related enquiries based on past business experience and standard industry practice must be stored for the duration of the regular statutory limitation period of three years (§ 195, 199 BGB (German Civil Code)).

Deadline begins at the end of the year: if a period does not expressly begin on a specific date and consist of at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the time at which the cancellation or other termination of the legal relationship takes effect.

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 Art. 15 to 21 GDPR:

• Right of objection: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If your personal data 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, which includes profiling to the extent that this profiling is related to such direct marketing.

• Right to withdraw consent: You have the right to withdraw your consent at any time.

• Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.

• Right to rectification: In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.

• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.

• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.

• Complaint to 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 the personal data concerning you infringes the provisions of the GDPR.

Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

• Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).

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

• Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.

• Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.

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

Further information on processing operations, procedures and services:

• Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a ‘web host’); legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR).

• Collection of access data and log files: Access to our online offer is logged in the form of server log files. The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, generally, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive DDoS attacks), and also to ensure the capacity of the servers and their stability;
Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Use of cookies
The term ‘cookies’ refers to functions that store information on users’ devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyse visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user’s consent in advance. If consent is not required, our legitimate interests provide the necessary legal basis. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offer. Consent can be revoked at any time. We provide clear information about their scope of our cookies and which cookies are used.

Information on the legal bases for data protection: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and processes.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their device (e.g. browser or mobile application).

• Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, login status can be saved and favourite content can be displayed directly when the user returns to a website. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that the cookies are permanent and that the storage duration can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements, including by means of the privacy settings in their browser.

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

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

• Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Consent (Art. 6(1)(1)(a) GDPR).
Further information on processing operations, procedures and services:

• Processing of cookie data on the basis of consent: We use a consent management solution that obtains user consent to the use of cookies or the procedures and providers named in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and similar technologies that are used to store, read and process information on users’ end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid a repeated request and to be able to provide proof of consent in accordance with the legal requirements. The storage takes place on the server side and/or in a cookie (opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for a period of up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, system and end device used; legal bases: Consent (Art. 6(1)(1)(a) GDPR).

Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons is processed insofar as this is necessary to answer the contact enquiries and any measures requested.

• Types of data processed: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and posts as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).

• Data subjects: Communication partners.

• Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.

• Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.

• Legal bases: Legitimate interests (Art. 6(1)(1)(f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR).
Further information on processing operations, procedures and services:

• Contact form: When contacting us via our contact form, email or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This usually includes details such as name, contact information and, if applicable, other information that is provided to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication;
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6(1)(1)(b) GDPR), legitimate interests (Art. 6(1)(1)(f) GDPR).

Plugins and embedded functions and content

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as ‘third-party providers’). This may include content such as graphics, videos or city maps (hereinafter uniformly referred to as ‘content’).

The integration always requires that the third-party providers of this content process the IP address of the user, as they cannot send the content to their browser without that IP address. The IP address is therefore required to display this content or function. We endeavour only to use content from providers who use the IP address for the sole purpose of delivering that content. Third-party providers may also use ‘pixel tags’ (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymised information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, but may also be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this Privacy Policy.

• Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).

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

• Purposes of processing: Provision of our online offer and user-friendliness.

• Retention and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’. Storage of cookies for up to 2 years (unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).

• Legal bases: Consent (Art. 6(1)(1)(a) GDPR). Legitimate interests (Art. 6(1)(1)(f) GDPR).
Further information on processing operations, procedures and services:

• Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of display or user-friendliness of our online offer). The respective providers collect the IP address of the user and can process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimisation of their service. – We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of display or user-friendliness of our online offer). The respective providers collect the IP address of the user and can process it for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimisation of their service; legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR).

• Google Fonts (provision on own server): Provision of font files for the purpose of a user-friendly presentation of our online offer; service provider: Google Fonts are hosted on our server, no data is transmitted to Google; legal basis: Legitimate interests (Art. 6(1)(1)(f) GDPR).

Changes and updates
We ask you to inform yourself regularly about the content of our Privacy Policy. We will amend the Privacy Policy as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of co-operation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this Privacy Policy, please note that the addresses may change over time, so please check the information before contacting them.
Definitions of terms
This section provides you with an overview of the terms used in this Privacy Policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.

• Inventory data: Inventory data includes essential information that is necessary for the identification and management of 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 people and services, facilities or systems by enabling clear assignment and communication.

• Content data: Content data includes information that is generated in the course of creating, editing and publishing content of all kinds. This category of data can 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, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication data

• Contact details: Contact data is essential information that enables communication with people or organisations. They include 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 process data: Metadata, communication data and process data are categories that contain information about the way data is processed, transmitted and managed. Metadata, also known as data about data, includes information that describes the context, origin and structure of other data. It can contain information on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Process data describes the processes and procedures within systems or organisations, 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 records how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they use to navigate through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimising user experiences, personalising content and improving products or services. In addition, usage data plays a crucial role in recognising trends, preferences and potential problem areas within digital offerings

• Personal data: Personal data refers to 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 that have been logged in a system or network. This data typically contains 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 to analyse system problems, for security monitoring or to create performance reports.

• Data controller: The ‘data controller’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

• Processing: ‘Processing’ means any operation or set of operations which is performed in connection with personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, be it collecting, analysing, storing, transmitting or deleting.

Original German version created with Datenschutz-Generator.de by Dr Thomas Schwenke