Privacy Policy

[Disclaimer: This is a translation of our Privacy Policy originally written in German. In the event of legal proceedings, the original German version applies, as does German law.]

 

Privacy Policy

 

of minubo GmbH, hereinafter “minubo”.

Last updated: October 12, 2026

I. Privacy Notice

1. General Information

The protection of your personal data is very important to us. Naturally, we comply with the provisions of the EU General Data Protection Regulation (GDPR). The following notice provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data with which you can be personally identified.

2. Data Controller

The entity responsible for data processing is:

minubo GmbH
represented by Managing Director Andreas Fischer
Schwanenwik 24
22087 Hamburg
Germany

Phone: +49 (0) 40 3980675 0
Email: contact@minubo.com

__________

In accordance with Article 37 GDPR, we have appointed an external Data Protection Officer.
Our Data Protection Officer and our privacy team can be reached at the following contact address:

Konstantin Pflüger
Anywhere digital GmbH
Hoheluftchaussee 40 A
20253 Hamburg

Tel.: +49 (0)40 38 99 500
Email: datenschutz@minubo.com

3. Data Security

We have taken technical and organizational measures to protect the data entrusted to us as best as possible against access by third parties. Our servers are protected by technical measures. Likewise, role and authorization concepts, as well as backup and recovery procedures, are standard for us. We use encryption procedures using TLS encryption (you can recognize this method by the address bar starting with https://).

We would like to point out that data transmission over the Internet (e.g., when communicating by email) can always have security gaps and may occur without transport encryption depending on the mail server. Complete protection against third-party access is not possible.

4. Legal Basis and Purpose

In order to ensure the operation of our website and to inform you optimally, we use technical options to monitor the use of our website. This data collection is explained separately in this policy.

The legal basis for this processing is legitimate interest (Article 6 (1) (f) GDPR) to operate our service professionally and securely.

We point out that according to Art. 21 GDPR, you have the right to object in cases where personal data is processed pursuant to Art. 6 (1) (e) GDPR or Art. 6 (1) (f) GDPR. In the event that you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests.

The objection can be submitted in writing or by email to the contact address specified above.

For the use of contact forms or email, the legal basis arises from our legitimate interest under Art. 6 (1) (f) GDPR to enable a quick and easy way to contact us.

Furthermore, there are situations in which you wish to share personal data with us.

In this case, we will ask you for consent pursuant to Art. 6 (1) (a) GDPR for processing. The consent granted by you can be revoked at any time. The lawfulness of the processing carried out prior to the revocation remains unaffected by the revocation.

5. Summary: What Data Is Collected?

A detailed description can be found in our Data Collection section.

  • a) Cookies
  • b) Server Log Files
  • c) Use of Hotjar
  • d) Use of Google Services
  • e) Data Collection during Job Applications
    f) Collection and Use of Data during Registration
  • g) Collection and Processing when Using the Contact Form
  • h) Implementation and Use of HubSpot
  • i) Newsletter
  • j) CRM and Support
  • k) Use and Processing when Using the minubo Academy
  • l) Use of Clockify (Time Tracking)
  • m) Use of Video Conferencing and Recording Tools
  • n) Webinars
  • o) minubo Business Intelligence Software Solutions

6. Recipients / Disclosure of Personal Data

In principle, we do not pass data on to third parties, especially not for promotional purposes. However, our website is hosted by an external service provider. In this context, your personal data collected on our website is stored on the service provider's servers.

Our hoster is deployed for the purpose of contract fulfillment and processing pursuant to Art. 6 (1) (b) GDPR in order to provide our offer safely and quickly.

The following service partners are involved in processing:

HubSpot Ireland Ltd
Ground Floor, Two Dockland Central, Guild Street
Dublin 1, Co. Dublin
Ireland
Phone: +353 1 5187500

In doing so, all data protection measures are complied with and the service partner will only process your data to the extent that this is necessary for the service obligation to be fulfilled.

We carefully select our service partners and only commission those who offer sufficient guarantees that appropriate technical and organizational measures are implemented in accordance with the GDPR and the German Federal Data Protection Act (BDSG). To ensure maximum security, our service providers are bound by instructions, committed to confidentiality, subject to regular reviews, and have concluded necessary Data Processing Agreements pursuant to Art. 28 GDPR with us.

7. Data Types and Categories of Data

The following types of data are regularly subject to processing, depending on what data was disclosed to us:

  • IP addresses
  • Contact requests
  • Meta and communication data
  • Contractual data
  • Contact details
  • Names
  • Website access data
  • Other data generated via a website

8. Information on Data Subject Rights

a) Revocation of Consent

Many data processing operations are only possible with your express consent. You can revoke consent you have already granted at any time. An informal email to us is sufficient for this purpose. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.

b) Right of Access by the Data Subject

You have the right to free information, rectification, erasure, or restriction of processing of your stored personal data at any time.

Furthermore, you have the right to rectification of incorrect or incomplete stored data.

c) Right to Lodge a Complaint

Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with a supervisory authority. (See contact details below)

9. Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of data protection law, the data subject has a right to lodge a complaint with a supervisory authority.

The supervisory authority competent for us in data protection matters is:

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22, 20459 Hamburg
mailbox@datenschutz.hamburg.de

10. Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a standard, machine-readable format.

11. Access, Restriction, Erasure

Within the framework of applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing, and, if applicable, a right to rectification, restriction, or erasure of this data. Statutory retention and documentation periods must be observed. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time using the address provided under contact details.

12. Right to Restriction of Processing

“Restriction of processing” refers to methods for limiting the processing of personal data. In this case, the data subject's data is temporarily blocked and no longer displayed or processed. You have the right to request this restriction of processing if one of the following conditions applies:

  • The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data,
  • The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead,
  • We no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise, or defense of legal claims,
  • You have objected to processing based on legitimate interests on our part, pending the verification whether our legitimate grounds override yours.
  • If processing has been restricted at your request, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the Union or of a Member State of the European Union.

 

13. Right to Object

You can object to processing by us at any time if the processing is carried out for the performance of a task in the public interest or in the exercise of official authority, or for the purposes of legitimate interests pursued by the controller (Article 6 (1) (e) or (f) GDPR). This also applies to profiling based on those provisions. Under certain circumstances, however, you may then no longer be able to use our services.

14. Analytics Tools and Third-Party Tools

When visiting our website, your browsing behavior may be statistically evaluated. This occurs primarily using so-called analytics programs. The analysis of your browsing behavior is generally anonymous. You can object to this analysis or prevent it by not using certain tools. Detailed information on this can be found in the following Privacy Policy.

15. External Links to Websites of Other Providers Outside Our Responsibility

Our website contains external links to pages of other providers.

If you click on external links, we point out that these are not under our responsibility and that their content differs from ours. We have no influence on which data protection policies are pursued and assume no responsibility or liability for them.

Please check whether your data is treated confidentially before passing on your data to websites of other providers, as responsibility then lies with the provider of the linked page.

Please also note that the transfer may involve unsafe third countries without an adequate level of data protection, posing a risk to the protection of your data. There, data may potentially be used for control and surveillance purposes under certain circumstances.

If you do not wish this, do not click on the link. If you nevertheless wish to use the link target, click on the external link and your data will be transmitted accordingly to the link target.

16. Data Transfer to Third Countries

When using our website and services from minubo, personal data may be transferred to countries outside the European Union (third countries). Insofar as no adequacy decision by the European Commission exists for the respective country, we ensure that the transfer takes place on the basis of suitable safeguards pursuant to Art. 44 et seq. GDPR (such as standard contractual clauses) or other statutory exceptions.

Special notes on US transfers: The transfer of data to the USA for service providers certified under the EU-US Data Privacy Framework (DPF) is based on the adequacy decision of the EU Commission of July 10, 2023 (Art. 45 GDPR). Please check the certification of the respective provider on the official DPF Website. For all other US service providers, the following continues to apply: There is a risk of access by US authorities for control and surveillance purposes, against which no equivalent legal protection may exist as in the EU.

II. Data Collection on Our Website


a) Cookies

The internet pages partially use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offering more user-friendly, effective, and secure. Cookies are small text files stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies”. They are automatically deleted after your visit. Other cookies remain stored on your end device until you delete them. These cookies allow us to recognize your browser on your next visit.

You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for specific cases or generally, and activate the automatic deletion of cookies when closing the browser. Deactivating cookies may limit the functionality of this website.

Cookies necessary to carry out the electronic communication process or to provide certain functions desired by you are stored on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. Insofar as other cookies (e.g., cookies for analyzing your browsing behavior) are stored, these are treated separately in this Privacy Policy.

You have the option to decide on the setting of cookies in the context of our offering via the “Consent Banner”.

b) Server Log Files

The provider of the pages automatically collects and stores information that your browser automatically transmits to us in so-called server log files.

These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not merged with other data sources.

The legal basis for this processing is legitimate interest (Article 6 (1) (f) GDPR) to operate this website professionally and securely.

When using this general data and information, minubo draws no conclusions about the data subject. Rather, this information is required to (1) deliver the content of our website correctly, (2) optimize the content of our website and advertising for it, (3) ensure the long-term functionality of our information technology systems and website technology, and (4) provide law enforcement authorities with the necessary information for prosecution in the event of a cyberattack. Therefore, this anonymously collected data and information is analyzed statistically by minubo and further with the goal of increasing data protection and data security in our company to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

c) Use of Hotjar

minubo has integrated services of Hotjar Ltd. on this website. “Hotjar” is an analytics tool through which website operators can evaluate the online behavior of their users. Possible tools offered by the platform are heatmaps, user surveys, and funnel tracking. Through these, website operators can reveal clicks, scroll heights, and mouse movements of users, for example. With the data obtained, they can improve the functionality and user-friendliness of their website.

Purpose of processing: Hotjar services enable the analysis of visitor flows and their behavior on our website. Hotjar uses the acquired data and information, among other things, to evaluate the use of the website in order to compile simple data visualizations, such as heatmaps, for us. In this way, we can analyze where we can further optimize the user experience.

Legal basis: Consent pursuant to Art. 6 (1) (a) GDPR, which is obtained via the cookie banner.

Data categories: Hotjar uses cookies and tracking codes to collect user data for website operators. In doing so, the tracking codes collect, among other things:

  • the IP address of the device (anonymized collection and storage by collecting only the first 3 octets of the IP),
  • the device type,
  • the screen size of the device,
  • geographic location (country),
  • the language used on the website,
  • the subpages visited on the website,
  • the referring domain, and
  • date and time of the website visit.

Provider: The operating company of Hotjar services is Hotjar Ltd., Dragonara business centre, 5th floor, Dragonara road, Paceville St Julian’s, STJ 3141, Malta.

All data collected is stored on servers in Ireland (EU) according to Hotjar statements. Hotjar has self-imposed a data storage period of 365 days, after which the collected data is automatically deleted. No personal data is stored by Hotjar for analysis, and the company follows the guideline “We track behaviour, not individuals”.

Data subjects additionally have the option to object to tracking by Hotjar. For this purpose, the data subject must call up the link https://www.hotjar.com/policies/do-not-track/ from each of the internet browsers used by them and adjust the desired settings ('Opt-Out').

Furthermore, the data subject has the option to prevent the setting of cookies by our website at any time, as already described above, by means of a corresponding setting ('Do-Not-Track') of the internet browser used and thus permanently object to the setting of cookies. In addition, a cookie already set by Hotjar can be deleted at any time via the internet browser or other software programs.

d) Use of Google Services

Insofar as personal data is transferred to the USA when using Google services, we base this transfer on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider [Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA] is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45 (1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

1. Use of Google Tag Manager

We use the “Google Tag Manager” service from the provider Google Inc. This is an auxiliary service and facilitates the integration of tools, so that data is collected only for technically necessary purposes.

Purpose of processing: Tag management of integrated tools on the website.

Legal basis: Consent pursuant to Art. 6 (1) (a) GDPR, obtained via the cookie banner. The data is deleted as soon as it is no longer required, but at the latest 14 days after retrieval.

Further information and the applicable privacy provisions of Google can be retrieved at https://policies.google.com/privacy?hl=de&gl=de.

2. Use of Google Analytics

minubo has integrated the “Google Analytics” component (with anonymization function) on the website and blog. Google Analytics is a web analytics service that uses the acquired data and information, among other things, to evaluate the use of our website in order to compile online reports for us showing activities on our website, and to provide other services related to website usage.

Purpose of processing: The Google Analytics component is used to analyze visitor flows on our website in order to operate it professionally. Web analysis is mainly used for optimizing the website and for cost-benefit analysis of internet advertising.

Legal basis: Consent pursuant to Art. 6 (1) (a) GDPR, obtained via the cookie banner.

Data categories: Web analytics is used to collect and evaluate data about the behavior of website visitors. Among other things, data is recorded on which website a data subject came from (so-called referrer), which subpages were accessed, or how often and for what duration a subpage was viewed. minubo uses the suffix “_gat._anonymizeIp” for web analytics via Google Analytics. By means of this suffix, the IP address of the data subject's internet connection is shortened and anonymized by Google if access to our website occurs from a Member State of the European Union or another state party to the Agreement on the European Economic Area.

Google Analytics sets a cookie on the data subject's information technology system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the data subject's IT system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google gains knowledge of personal data, such as the data subject's IP address, which serves Google, among other things, to understand the origin of visitors and clicks and subsequently enable commission settlements.

By means of the cookie, personal information, such as access time, the location from which access originated, and the frequency of visits to our website by the data subject, is stored. Upon each visit to our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass this personal data collected through the technical procedure on to third parties under certain circumstances.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the data subject's information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website, as well as the processing of this data by Google. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout.

This browser add-on informs Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject's information technology system is deleted, formatted, or newly installed at a later point in time, a reinstallation of the browser add-on must be performed by the data subject to disable Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, the option of reinstallation or reactivation of the browser add-on exists.

The criterion for the duration of the storage of personal data is, in addition to any agreed contract term, the respective statutory retention period. After expiration of the period, the corresponding data is routinely erased provided it is no longer required for contract performance or initiation.

Another option for deactivating Google Analytics on mobile devices is available directly with the provider Google Analytics.

Further information and Google's applicable privacy provisions can be retrieved under https://policies.google.com/privacy?hl=de&gl=de and https://marketingplatform.google.com/about/analytics/terms/de/.

Google Analytics is explained in more detail under this link: https://marketingplatform.google.com/intl/en_uk/about/analytics/.

e) Data Collection during Job Applications

minubo collects and processes personal data from applicants for the purpose of handling the application procedure pursuant to Art. 6 (1) (f) GDPR.

The processing can also be carried out electronically. This is particularly the case when an applicant transmits corresponding application documents electronically, for example by email or via a web form located on the website, to the controller.

If minubo concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with statutory regulations pursuant to Art. 88 GDPR in conjunction with Section 26 BDSG.

If no employment contract is concluded by minubo with the applicant, the application documents will be automatically deleted six months after notification of the rejection decision, provided that the applicant has not granted consent for further processing pursuant to Art. 6 (1) (a) GDPR. The six-month period arises from defending against potential claims under the General Equal Treatment Act (Section 15 (4) AGG). The data is then retained for evidence purposes and deleted after the six-month period.

f) Collection and Use of Data during Registration

You have the option to register with us. This is voluntary and serves the controller to offer the data subject content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to contact minubo at any time to modify the personal data provided during registration or to have it completely erased from the controller's data records.

The legal basis for this is Article 6 (1) (a) GDPR. The consent granted by you can be revoked at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.

Furthermore, by registering on the website of the controller, the IP address assigned by the Internet Service Provider (ISP) of the data subject, as well as the date and time of registration, are stored. The storage of this data takes place against the background that this is the only way to prevent misuse of our services and, if necessary, to enable committed criminal offenses to be investigated.

In this respect, the storage of this data is necessary to secure the controller. In principle, this data is not disclosed to third parties unless there is a statutory obligation to pass it on or the disclosure serves criminal prosecution.

g) Collection and Processing when Using the Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details provided by you there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We will not pass on this data without your consent.

The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes (including contact by minubo). The controller may arrange for disclosure to one or more processors who also use the personal data exclusively for internal use attributable to the controller. No disclosure beyond this to third parties takes place.

The processing of data entered into the contact form thus takes place exclusively on the basis of your consent (Art. 6 (1) (a) GDPR). You can revoke this consent at any time. An informal message by email to us is sufficient. The lawfulness of the data processing operations carried out prior to the revocation remains unaffected by the revocation.

The data entered by you in the contact form will remain with us until you request erasure, revoke your consent for storage, or the purpose for data storage no longer applies (e.g., after completion of your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

h) Implementation and Use of HubSpot

minubo uses “HubSpot” for our online marketing activities. This is an integrated software solution covering various aspects of online marketing.

Purpose of processing: Provision of the website and associated functions, as well as planning, dispatch, and optimization of marketing measures. These include, among others:
Content Management (website and blog)
Email Marketing (newsletter and automated mailings, e.g. for providing downloads)
Social Media Publishing & Reporting
Reporting (e.g. traffic sources, access, etc. …)
Contact Management (e.g. user segmentation & CRM)
Landing Pages and contact forms

Legal basis: Legitimate interest pursuant to Art. 6 (1) (f) GDPR.

Data categories: Via the sign-up service, visitors to our website can download content and provide their contact information as well as further demographic information. See also g) Collection and Processing when Using the Contact Form, and i) Newsletter.

This information as well as the content of our website are stored on servers of our software partner HubSpot. It can be used by us to contact visitors to our website and to determine which services of our company are of interest to them. All information collected by us is subject to this Privacy Policy.

Insofar as personal data is transferred to the USA when using HubSpot, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider HubSpot is a software company from the USA with a subsidiary in Ireland [HubSpot Ireland Ltd, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Co. Dublin, Ireland, Phone: +353 1 5187500] and is certified under the DPF, thus committing to maintain an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45 (1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

More information on HubSpot's privacy policy »

More information from HubSpot regarding EU data protection provisions »

More information on the cookies used by HubSpot can be found here & here »

i) Newsletter

minubo informs its customers, business partners, and interested parties at regular intervals by way of a newsletter about company offers, which can be subscribed to for all or selected topics.

Purpose of processing: The personal data collected in the context of registering for the newsletter will be used for sending our newsletter and for information surrounding changes or disruptions to our newsletter offer. Furthermore, subscribers may be contacted by minubo via email for sales purposes if a legitimate interest of minubo exists, e.g. the newsletter recipient shows strong interest in minubo's products/services through corresponding behavior.

Legal basis: Your consent pursuant to Art. 6 (1) (a) GDPR.

Data categories: The newsletter can generally only be received by the data subject if the data subject has a valid email address and registers for newsletter delivery. A confirmation email is sent for legal reasons to the email address registered by a data subject for the first time for newsletter delivery using the double opt-in procedure. This confirmation email serves to check whether the owner of the email address as the data subject authorized receipt of the newsletter. When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of a data subject's email address at a later date and therefore serves the legal protection of the controller.

Provider: For sending email campaigns, in particular newsletters, we rely on the provider “HubSpot”. For further information on this, see also above under “h) Deployment and Use of HubSpot”.

There is no disclosure of personal data collected as part of the newsletter service to third parties. The subscription to our newsletter can be canceled by the data subject at any time. The consent to store personal data granted to us by the data subject for newsletter delivery can be revoked at any time. For the purpose of canceling the subscription, a corresponding link can be found in each newsletter. Furthermore, the option exists to communicate this to the controller at any time in another way.

Newsletter Tracking

The newsletters of minubo contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of our newsletter contents to be carried out. Based on the embedded tracking pixel, minubo can recognize whether and when an email was opened by a data subject and which links in the email were called up by the data subject.

Such personal data collected via tracking pixels contained in newsletters is stored and evaluated by the controller to optimize newsletter dispatch and adapt future newsletter content even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent submitted via the double opt-in procedure. An unsubscription from receiving the newsletter is automatically interpreted by minubo as a revocation.

The legal basis arises from consent pursuant to Art. 6 (1) (a) GDPR, which is obtained via a mail link.

j) CRM and Support

minubo uses CRM systems and support portals to document contract initiation, contract execution, and customer support.

Purpose of processing: minubo collects and stores information on companies and employees of these companies that have entered into a contractual relationship with minubo or wish to do so in order to use one of minubo's various solution offerings.

Legal basis: Fulfillment of pre-contractual or contractual obligations pursuant to Art. 6 (1) (b) GDPR.

Data categories: Personal data in these systems is limited to business contact details such as first name, last name, email address, role, title, and phone numbers.

The contractual partner for the CRM system is the US provider “Salesforce”. The technical service provider Salesforce is an offering of Salesforce.com, Inc., 415 Mission Street, 3rd Floor, San Francisco, CA 94105, USA. Insofar as personal data is transferred to the USA when using Salesforce, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider Salesforce is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45(1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

The contractual partner for the support system “Jira ServiceDesk” is the US provider “Atlassian”. The technical service provider Atlassian is an offering of Atlassian, Inc., 350 Bush Street, Level 13, San Francisco, CA, 94104, USA. Insofar as personal data is transferred to the USA when using Jira ServiceDesk, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider Atlassian is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45(1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

minubo provides every data subject with information upon request at any time as to what personal data is stored about the data subject. Furthermore, minubo rectifies or erases personal data at the request or notice of the data subject, provided no contractual or statutory retention obligations conflict with this. Both the Data Protection Officer and the respective account manager are available to the data subject as contact persons in this context.

k) Use and Processing when Using the minubo Academy

The minubo Academy is made available for conducting curated online learning courses, webinars, and training for customers and interested parties. Via the corresponding platform “Melting Spot”, participation can also be approved after registration, managed, and interacted with participants.

Purpose of processing: Provision of customer training and webinars, management of participants (e.g. registration confirmations, access data), monitoring training success.

Legal basis: Fulfillment of (pre-)contractual obligations pursuant to Art. 6 (1) (b) GDPR for providing content to customers or consent pursuant to Art. 6 (1) (a) GDPR for interested parties.

Data categories: During registration, business email address, first and last name, and role (if applicable) are collected and stored. Melting Spot processes this data on our behalf and uses it to provide and manage Academy access as well as to perform platform usage analytics. In this context, Melting Spot uses cookies and similar technologies to measure Academy usage (e.g., courses visited, videos watched, progress).

Provider: Melting Spot is an offering of Melting Spot, 203 Rue de Crimée, 75019 Paris, France.

The necessary Data Processing Agreements pursuant to Art. 28 GDPR have been concluded with Melting Spot. It is a European company, and processing generally takes place within the EU.

The consent granted by the data subject can be revoked at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected.

 

l) Use of Clockify (Time Tracking)

minubo uses the tool “Clockify” for recording and documenting work hours performed by employees on customer projects and internal activities. The recording serves internal administration, billing of services, and compliance with contractual duties.

Purpose of processing: Working time tracking for internal purposes and billing to customers; fulfillment of proof obligations.

Legal basis: Processing is necessary for the performance of a contract and takes place on the basis of Art. 6 (1) (b) GDPR (for billing and contract execution) or Art. 6 (1) (c) GDPR (compliance with a legal obligation, e.g. record-keeping requirements under labor law).

Data categories: Name and email address of the employee, recorded work time, start and end times, assigned project or customer, and description of the service performed.

Provider: CAKE.com Inc., 2100 Geng Rd STE 210, Palo Alto, CA 94303, USA

Insofar as personal data is transferred to the USA when using Clockify, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider CAKE is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45(1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

m) Use of Video Conferencing and Recording Tools

1. Google Meet

minubo processes personal data that we receive from our customers or other data subjects in online meetings within the framework of using “Google Meet”. If online meetings are to be recorded, this will be transparently communicated in advance and – where necessary – consent will be requested.

Purpose of processing: Communication with customers and interested parties in the form of video conferences.

Legal basis: Fulfillment of contractual or pre-contractual measures pursuant to Art. 6 (1) (b) GDPR.

Data categories: Relevant personal data includes personal details (name, phone number, and other contact details, meeting metadata: topic, description (optional), participant IP addresses, device/hardware information, as well as the IP address of your device). Furthermore, written communication in the chat function of Google Meet is recorded.

Google does not use customer data for advertising and does not sell it to third parties. Customer data is encrypted during transmission, and recordings stored in Google Drive are encrypted by default. There are no attention-tracking features or software in Google Meet.

We fundamentally erase personal data when there is no requirement for further storage. A requirement may exist in particular if the data is still needed to perform contractual services, or to verify, grant, or defend against warranty and guarantee claims. In the case of statutory retention obligations, erasure only comes into consideration after expiration of the respective retention obligation.

Insofar as personal data is transferred to the USA when using the Google service, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider [Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA] is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45(1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

Note: Insofar as you call up the Google Meet website, the provider of Google Meet is responsible for data processing. Calling up the website is only necessary for using Google Meet to download the software for using Google Meet. However, downloading software is not required to conduct video conferences.

https://support.google.com/meet/answer/9852160?hl=de&ref_topic=10632347

 2. Microsoft Teams

minubo processes personal data that we receive from our customers or other data subjects in online meetings within the framework of using “Microsoft Teams”. If online meetings are to be recorded, this will be transparently communicated in advance and – where necessary – consent will be requested.

Purpose of processing: Communication with customers and interested parties in the form of video conferences.

Legal basis: Fulfillment of contractual or pre-contractual measures pursuant to Art. 6 (1) (b) GDPR.

Data categories: Relevant personal data includes personal details (name, phone number, and other contact details, meeting metadata: topic, description (optional), participant IP addresses, device/hardware information, as well as the IP address of your device). Furthermore, written communication in the chat function of Microsoft Teams is recorded.

We fundamentally erase personal data when there is no requirement for further storage. A requirement may exist in particular if the data is still needed to perform contractual services, or to verify, grant, or defend against warranty and guarantee claims. In the case of statutory retention obligations, erasure only comes into consideration after expiration of the respective retention obligation.

Insofar as personal data is transferred to the USA when using Microsoft Teams, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider [Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA] is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45(1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

Further information and the applicable data protection provisions of Microsoft can be retrieved under https://privacy.microsoft.com/en-us/privacystatement.

3. Kickscale

minubo uses the service “Kickscale” to record and analyze video conferences with customers or interested parties.

Purpose of processing: Kickscale serves to structure and record mentioned requirements, questions, and other conversation content to improve product development and sales strategy, as well as for training sales staff.

Legal basis: Legitimate interest pursuant to Art. 6 (1) (f) GDPR in optimizing our business processes, products, and customer communication quality, as well as, where necessary, your consent pursuant to Art. 6 (1) (a) GDPR. We inform you in advance transparently about the recording and obtain – where necessary – your consent.

Data categories: Audio and video data of the conference are processed during recording and analysis. Metadata (such as date, duration, participant names, and email addresses) as well as conversation content are processed in this context.

Provider: Kickscale is an offering of Kickscale UG (haftungsbeschränkt), Lottbeker Weg 22, 22359 Hamburg, Germany.

Processing takes place within the EU/EEA. We have concluded a Data Processing Agreement pursuant to Art. 28 GDPR with Kickscale.

The data is erased as soon as it is no longer required for the specified purposes, usually at the latest after six months, provided no longer statutory retention periods exist or erasure takes place upon your request.

Further information on data processing by Kickscale can be retrieved under https://kickscale.com/privacy-policy.

n) Webinars

minubo processes personal data received from our customers or other data subjects when using the video conferencing tool “Zoom” from the US provider “Zoom Video Communications”.

Purpose of processing: Communication with customers and interested parties in the form of video conferences containing promotional and educational content.

Legal basis: Legitimate interest pursuant to Art. 6 (1) (f) GDPR to offer webinars, as well as your consent pursuant to Art. 6 (1) (a) GDPR.

Data categories: Relevant personal data includes personal details (name, phone number where applicable, and other contact details, meeting metadata: topic, description (optional), participant IP addresses, device/hardware information, as well as the IP address of your device). Furthermore, written communication in the chat function of Zoom is recorded.

Provider: Zoom Video Communications, Inc., 55 Almaden Blvd, San Jose, CA 95113, USA

Processing by the provider does not take place outside the EU, but has been restricted to server locations in Germany and the Netherlands.

Note: Insofar as you call up the website of Zoom Video Communications, the provider of Zoom Video Communications is responsible for data processing. Calling up the website is only required for using Zoom Video Communications, e.g. to download software for using Zoom Video Communications.

https://www.zoom.com/en/trust/privacy/

o) minubo Business Intelligence Software Solutions

1. Error & Performance Analysis

To ensure the stability and performance of our web-based minubo software solutions, we use the “Sentry” service from Functional Software, Inc.

Purpose of processing: Sentry serves our developers for error & performance monitoring by logging and analyzing crashes, errors, and application performance issues in real time.

Legal basis: Legitimate interest in a technically error-free and optimized operation of our software (Art. 6 (1) (f) GDPR) as well as performance of our contractual duties toward customers to whom we provide a functional software (Art. 6 (1) (b) GDPR).

Data categories: Relevant personal data includes IP address (for error localization), email address, and user ID of affected users to attribute the error to a user and thus a usage session.

The storage duration of collected data corresponds by default to that of the respective log file or associated event and is kept as short as possible, generally no longer than 90 days.

Insofar as personal data is transferred to the USA when using Sentry, we base this on the adequacy decision of the European Commission of July 10, 2023, pursuant to Art. 45 GDPR, the EU-US Data Privacy Framework (DPF). The provider [Functional Software, Inc. d/b/a Sentry 45 Fremont Street, 8th Floor, San Francisco, CA 94105] is certified under the DPF and has thus committed to maintaining an adequate level of data protection. The legal basis for the data transfer is therefore Art. 45 (1) GDPR. Information on the provider's certification can be found on the official DPF website of the U.S. Department of Commerce.

2. Using Our Free Demo Account

minubo offers its customers and business partners the use of a free demo account to test products in detail and obtain further information about the product.

The legal basis for this is contractual or pre-contractual measures pursuant to Art. 6 (1) (b) GDPR.

By registering for a demo account, the IP address assigned by the Internet Service Provider (ISP) of the data subject, as well as the date and time of registration, are stored. The storage of this data takes place against the background that this is the only way to prevent misuse of our services and, if necessary, to enable committed criminal offenses to be investigated. In this respect, the storage of this data is necessary to secure the controller. In principle, this data is not disclosed to third parties unless there is a statutory obligation to pass it on or the disclosure serves criminal prosecution.

The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes (including contact by minubo). The controller may arrange for disclosure to one or more processors who also use the personal data exclusively for internal use attributable to the controller. No disclosure beyond this to third parties takes place.

We fundamentally erase personal data when there is no requirement for further storage. A requirement may exist in particular if the data is still needed to perform contractual services, or to verify, grant, or defend against warranty and guarantee claims. In the case of statutory retention obligations, erasure only comes into consideration after expiration of the respective retention obligation.

 

3. Using the Web-Based Application minubo Suite

The Business Intelligence software is a web-based application (at app.minubo.com) that enables e-commerce and omni-channel retail companies to make company data transmitted via various interfaces accessible to their employees within the minubo Suite product, thereby promoting data-driven working in their organization. The legal basis for this is the contract pursuant to Art. 6 (1) (b) GDPR.

Cookies

Like the website minubo.com, the web-based application minubo Suite at app.minubo.com also uses and stores cookies. The cookie serves in particular to store session information after login.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies already set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our Business Intelligence software may be fully usable.

Login Data

Users of minubo Business Intelligence software receive access credentials created by minubo employees or their colleague responsible for user management in minubo, consisting of their business email address and an invitation link. The password can be created independently by users via this link.

Additionally, when setting up an account, the first and last name as well as the functional area of the respective employee are recorded and stored. Depending on the functional area, certain functions in the Business Intelligence software may be personalized for the respective functional area.

Log Files and User Tracking

The minubo Suite contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded into individual HTML pages of the web-based application to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of individual functions within the Suite. Based on the embedded tracking pixel, minubo can recognize whether and when a specific function in the Suite was executed by a data subject. Additionally, minubo measures the activity of the entire company within the Suite and the various functional areas of the respective customer company working with the Suite.

4. Using the Co-Analyst in the Web-Based Application minubo Suite

Following opt-in to AI functionalities and feature release for selected users by the customer, texts, prompts, and any uploaded attachments entered by users in the chat function of the minubo Co-Analyst within the web-based application minubo Suite are processed to provide requested analyses and answers.

The datasets provided for the Co-Analyst fundamentally contain no directly identifying personal data; these have been removed or – where necessary – exist only in hashed or pseudonymized form. However, we urgently advise users not to enter personal, confidential, or special categories of personal data within the meaning of Art. 9 GDPR, or other sensitive information into prompts or attachments.

Should users nevertheless transmit such data, minubo processes it as a processor exclusively on behalf of and according to the instructions of the respective controller to execute the chat request. For processing, we deploy a routing system (OpenRouter, Inc., 169 Madison Ave #2404, New York, NY 10016, USA), which acts as an AI gateway, forwarding requests exclusively to selected model providers and necessary for the operation, security, and billing of the service. In this context, only services and language models hosted within the European Union according to respective configurations, offering Zero Data Retention, and using transmitted content neither for model training nor for own or other purposes are integrated. Conversation contents, prompts, attachments, and answers generated from them are deleted immediately at the addressed services and language models upon completion of the respective request.

minubo erases conversation contents, prompts, attachments, and generated answers entered in the Co-Analyst after completion of possible follow-up questions or user support inquiries after 30 days, unless statutory obligations or technically necessary longer storage are required. The customer may suspend this deletion if conversation threads are pinned for reference within the application. Processing for minubo's own purposes does not take place.

5. Using the Web-Based Application Supplier Portal

The minubo Supplier Portal is a web-based application enabling e-commerce and omni-channel retail companies to make company data transmitted via diverse interfaces accessible in a curated and filtered manner to their suppliers within a dedicated portal, thus fostering supplier relationships. The legal basis for this is the contract pursuant to Art. 6 (1) (b) GDPR. This portal can also be embedded by the customer on their own website.

Cookies

Like the website minubo.com, the web-based Supplier Portal also uses and stores cookies. The cookie serves in particular to store session information after login.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies already set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our Business Intelligence software may be fully usable.

Login Data

Users of the minubo Supplier Portal receive access credentials created by minubo employees, consisting of their business email address and a secure random password. The password can subsequently be changed by users to a personal password.

Additionally, when setting up access, first and last name as well as functional area of the respective employee are recorded and stored. Depending on the functional area, certain functions in the Business Intelligence software may be personalized for the respective functional area.

Log Files and User Tracking

The Supplier Portal from minubo contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded into individual HTML pages of the web-based application to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of individual functions within the portal. Based on the embedded tracking pixel, minubo can recognize whether and when a specific function in the portal was executed by a data subject. Additionally, minubo measures the activity of the entire company within the portal and the various functional areas of the respective customer company working with the portal.

6. Using the minubo Store Monitor Application

The minubo Store Monitor is an application for tablets and smartphones that provides users with quick and intuitive access to key performance indicators and data based on company data in minubo software.

Data Storage on the End Device

Analogous to cookies in internet browsers, the minubo Store Monitor stores data on the user's respective end device, which also includes personal information. In addition to session information (technical authentication keys used to maintain the session after login) and search history (identification numbers of searched entities such as brands and product names), the user's business email address is also stored to avoid re-entry upon subsequent login.

Blocking this data storage is not possible. If the data subject wishes to object to the storage of the above-mentioned information on the end device, they must delete the application on their end device along with the data stored by the app.

Login Data

Users of minubo Store Monitor receive access credentials created by minubo employees or their colleague responsible for user management in minubo, consisting of their business email address and a secure random password. The password can subsequently be changed by users to a personal password.

Additionally, when setting up access, first and last name as well as functional area of the respective employee are recorded and stored. Depending on the functional area, certain functions in the Store Monitor may be personalized for the respective functional area.

Log Files and User Tracking

The Store Monitor from minubo contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded into individual pages of the mobile application to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of individual functions within the application. Based on the embedded tracking pixel, minubo can recognize whether and when a specific function in the Suite was executed by a data subject. Additionally, minubo measures the activity of the entire company within the application and the various functional areas of the respective customer company working with the application.

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