preamble

With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing 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 offering").

The terms used are not gender-specific.

As of: February 27, 2025

Table of Contents

• preamble
• Person responsible
• Overview of processing
• Relevant legal bases
• Security measures
• Transmission of personal data
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Provision of the online service and web hosting
• Use of cookies
• Contact and inquiry management
• Change and update
• Definitions of terms

Person responsible

Panorama Europe GmbH
Fichtenstrasse 70
40233 Düsseldorf
Germany

Email address: mail@espadrij.com

Managing Director Felix Staeudinger

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

• Inventory data.
• Contact details.
• Content data.
• Usage data.
• Meta, communication and procedural data.
• Log data.

Categories of data subjects

• Communication partner.
• Users.

Purposes of processing

• Communication.
• Security measures.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online offering and user-friendliness.
• Information technology infrastructure.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases under the GDPR on 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 apply in individual cases, we will inform you of these in the privacy policy.

• Consent (Article 6 (1) (a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
• Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
• Legitimate interests (Article 6 (1) (f) GDPR) - processing is necessary to protect the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require protection of personal data do not prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (BDSG). The BDSG contains, in particular, special provisions on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of individual federal states may apply.

Security 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, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from 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 with TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized 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 transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may happen that this data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

Data processing in third countries: If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 (2) (c) GDPR), express consent or in the case of contractually or legally required transfer (Art. 49 (1) GDPR). We will also inform you of the basis for third-country transfers from the individual providers in the third country, with the adequacy decisions taking precedence. Information on third-country transfers and existing 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=de. Within the framework of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain US companies as secure within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In the privacy policy, we inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consent is revoked or there are no further legal grounds for processing. This applies to cases where the original processing purpose no longer applies or the data is no longer needed. 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 retained for commercial or tax law reasons or whose storage is necessary for legal proceedings or to protect the rights of other natural or legal persons must be archived accordingly.

Our privacy policy contains additional information on the retention and deletion of data that applies specifically to certain processing operations.

If there are multiple details regarding the retention period or deletion period for a given date, the longest period always applies.

If a period does not explicitly begin on a specific date and is 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 which data is stored, the event triggering the period is the effective date of the termination or other termination of the legal relationship.

We process data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons only for the reasons that justify its storage.

Further information on processing procedures, methods and services:

• Retention and deletion of data: The following general periods apply to retention and archiving under German law:
  • 10 years - retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents necessary for their understanding (Section 147 (1) No. 1 in conjunction with Section 3 AO, Section 14b (1) UStG, Section 257 (1) No. 1 in conjunction with Section 4 HGB).
  • 8 years - accounting documents, such as invoices and cost receipts (Section 147 Paragraph 1 No. 4 and 4a in conjunction with Paragraph 3 Sentence 1 AO and Section 257 Paragraph 1 No. 4 in conjunction with Paragraph 4 HGB).
  • 6 years - Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly wage slips, operating statements, calculation documents, price labels, but also payroll documents insofar as they are not already accounting documents and cash register slips (Section 147 (1) Nos. 2, 3, 5 in conjunction with Section 3 AO, Section 257 (1) Nos. 2 and 3 in conjunction with Section 4 HGB).
  • 3 years - Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

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 Articles 15 to 21 GDPR:

• Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw 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: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
• Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, 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 statutory provisions.
• Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
• Complaint to a 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 personal data concerning you violates the provisions of the GDPR.

Provision of the online service and web hosting

We process user data 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 procedural data (e.g., IP addresses, time information, identification numbers, persons involved); protocol data (e.g., log files regarding 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 services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

• Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also called a "web host") or obtain from other sources; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
• Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files." Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.

Use of cookies

The term "cookies" refers to functions that store and retrieve information from users' end devices. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows. We use cookies in accordance with legal regulations. Where necessary, we obtain user consent in advance. If consent is not required, we rely on our legitimate interests. This applies when storing and retrieving information is essential to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope of cookies and which cookies are used.

Notes on data protection law: Whether we process personal data using cookies depends on consent. If consent is 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, the following types of cookies are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their device (e.g. browser or mobile application).
• Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected using cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period 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 also object to processing in accordance with the legal requirements, including by using the privacy settings of their browser.

• Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
• Data subjects: Users (e.g. website visitors, users of online services).
• Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).

Further information on processing procedures, methods and services:

• Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers named within 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 used to store, read, and process information on users' end devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. Consent declarations are saved to avoid repeated queries and to be able to provide evidence of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using similar technologies in order to be able to assign consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: Consent is stored for 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 about the browser, system, and device used. Legal basis: Consent (Art. 6 (1) (a) GDPR).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

• Types of data processed: Inventory data (e.g., full name, home address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions as well as related information, such as 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 procedural data (e.g., IP addresses, time information, identification numbers, persons involved).
• Data subjects: communication partners.
• Purposes of processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section "General information on data storage and deletion".
• Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, methods and services:

• Contact form: When you contact us via our contact form, by email, or other communication channels, we process the personal data you provide to answer and process your request. This generally includes information such as your 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 contact and communication; legal bases: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Change and update

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. To the extent that the terms are defined by law, the legal definitions apply. The following explanations, however, are intended primarily to facilitate understanding.

• Inventory data: Inventory data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and unique identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unambiguous assignment and communication.
• Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. 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 itself but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
• Contact details: Contact details are essential information that enables communication with individuals or organizations. They include, among other things, telephone numbers, postal addresses, and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
• Metadata, communication data, and procedural data: Metadata, communication data, and procedural data are categories that contain information about how 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 include details about file size, creation date, document author, and change histories. Communication data captures the exchange of information between users across different channels, such as email traffic, call logs, social media messages, and chat histories, including the people involved, timestamps, and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review events.
• Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a broad range of information, including how users use applications, which features they prefer, how long they stay on certain pages, and the paths they take 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 analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
• Personal data: "Personal data" means 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 logged on a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about a system's usage or operation. Log data is often used to analyze system problems, for security monitoring, or for generating performance reports.
• Controller: The "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
• Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.