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 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 services").
The terms used are not gender-specific.
As of: May 25, 2026
Table of Contents
Controller
Thomas Oberhoff
Zedernweg 44
50226 Frechen
Germany
Authorized Representative: Thomas Oberhoff
Email Address: mail@courtle.app
Legal Notice: courtle.app
Overview of Processing Activities
The following overview summarizes the types of processed data and the purposes of their processing, and refers to the data subjects.
Types of Processed Data
- Master data (e.g., names, addresses).
- Employee data.
- Contact data (e.g., email, telephone numbers).
- Content data (e.g., text entries, form contents).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta, communication, and process data (e.g., IP addresses, device information).
- Log data (e.g., log files regarding logins or data retrieval).
Categories of Data Subjects
- Employees.
- Communication partners.
- Users (e.g., website visitors, users of online services).
- Third parties.
- Whistleblowers.
Purposes of Processing
- Communication.
- Security measures.
- Organizational and administrative procedures.
- Feedback (e.g., collecting feedback via online forms).
- Provision of our online services and user-friendliness.
- Information technology infrastructure (operation and provision of information systems and technical devices).
- Whistleblower protection.
Relevant Legal Bases
Relevant legal bases under the GDPR: Below is an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations in your or our country of residence or domicile may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of them in this privacy policy.
- Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 (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.
- Compliance with a legal obligation (Art. 6 (1) (c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 (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 regulations on data protection apply in Germany. This includes in particular the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special regulations on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states (Landesdatenschutzgesetze) may apply.
Security Measures
We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, transmission, securing availability, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and response to data threats. We also consider the protection of personal data as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect the data of users 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), 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. When 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 transmitted securely and in encrypted form.
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 occurs in the context of using third-party services or disclosing/transferring data to other persons, bodies or companies (which becomes recognizable from the postal address of the respective provider or if explicitly mentioned in this privacy policy), this is always done in accordance with legal requirements.
For data transfers to the US, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the EU Commission on July 10, 2023. In addition, we have concluded Standard Contractual Clauses (SCC) with the respective providers, which comply with the specifications of the EU Commission and establish contractual obligations to protect your data.
This dual protection ensures comprehensive security for your data: the DPF forms the primary level of protection, while the Standard Contractual Clauses serve as additional security. In the event of changes to the DPF, the Standard Contractual Clauses act as a reliable fallback option. This ensures that your data remains appropriately protected even in the event of political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and whether Standard Contractual Clauses are in place. Further information on the DPF and a list of certified companies can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/.
For data transfers to other third countries, appropriate security measures apply, in particular Standard Contractual Clauses, explicit consent, or legally required transfers. Information on third country transfers and existing adequacy decisions can be found on the EU Commission website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en.
General Information on Data Storage and Deletion
We delete personal data that we process in accordance with legal regulations as soon as the underlying consent is revoked or no other legal bases for processing exist. This applies to cases where the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule exist if legal obligations or specific interests require a longer retention or archiving of the data.
In particular, data that must be kept for commercial or tax reasons, or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person, must be archived accordingly.
Our data protection notices contain additional information on the storage and deletion of data that applies specifically to certain processing activities.
If several specifications are given for the retention period or deletion deadlines of data, the longest period is always decisive. Data that is no longer kept for the originally intended purpose, but due to legal requirements or other reasons, is processed by us exclusively for the reasons that justify its retention.
Retention and deletion of data: The following general deadlines 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 working instructions and other organizational documents required to understand them (§ 147 (1) No. 1 in conjunction with (3) AO (German Fiscal Code), § 14b (1) UStG (German Value Added Tax Act), § 257 (1) No. 1 in conjunction with (4) HGB (German Commercial Code)).
- 8 years - Booking vouchers, such as invoices and expense receipts (§ 147 (1) No. 4 and 4a in conjunction with (3) sentence 1 AO, and § 257 (1) No. 4 in conjunction with (4) HGB).
- 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents, insofar as they are of importance for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price tags, but also payroll documents, insofar as they are not already booking vouchers, and cash register strips (§ 147 (1) No. 2, 3, 5 in conjunction with (3) AO, § 257 (1) No. 2 and 3 in conjunction with (4) HGB).
- 3 years - Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related inquiries, based on past business experience and standard industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB (German Civil Code)).
Start of period at the end of the year: Unless a period explicitly begins on a specific date and is at least one year long, it starts automatically at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships under which data is stored, the triggering event is the time when the termination or other end of the legal relationship becomes effective.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) (e) or (f) GDPR, including profiling based on those provisions. If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent given at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right to obtain the completion of incomplete data or the rectification of inaccurate data concerning you in accordance with legal requirements.
- Right to erasure and restriction of processing: You have the right to obtain the erasure of personal data concerning you without undue delay, or alternatively to obtain restriction of processing of the data in accordance with legal requirements.
- Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller in accordance with legal requirements.
- Right to lodge a complaint with 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 infringes the GDPR.
Provision of Online Services and Web Hosting
We process the data of users 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 processed data: Usage data (e.g., pages visited, interest in content, access times); Meta, communication, and process data (e.g., IP addresses, access times, device information). Log data (e.g., server log files containing logins or access times).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; Information technology infrastructure (operation and provision of information systems, computers, servers, etc.). Security measures.
- Storage and deletion: Deletion in accordance with the details in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing activities, procedures, and services:
- Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
- Provision of online services on own/dedicated server hardware: For the provision of our online services, we use server hardware operated by us as well as the associated storage space, computing capacity, and software; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
- Collection of access data and log files: Access to our online services is logged in the form of so-called "server log files". The server log files may include the address and name of the retrieved websites and files, date and time of retrieval, transmitted data volumes, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. Server log files can be used on the one hand for security purposes, e.g., to prevent server overload (in particular in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure server utilization and stability; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.
- netcup: Services in the field of providing information technology infrastructure and associated services (e.g., storage space and/or computing capacities); Service Provider: netcup GmbH, Daimlerstraße 25, D-76185 Karlsruhe, Germany; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.netcup.de/; Privacy Policy: https://www.netcup.de/kontakt/datenschutzerklaerung.php. Data Processing Agreement: https://helpcenter.netcup.com/en/wiki/general/avv/.
Contact and Inquiry Management
When contacting us (e.g., by mail, contact form, email, telephone, or via social media) as well as in the context of existing user and business relationships, the details of the inquiring persons are processed to the extent necessary to respond to the contact inquiries and any requested measures.
- Types of processed data: Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as related information, such as authorship or time of creation). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online forms). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the details in the section "General Information on Data Storage and Deletion".
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR).
Further information on processing activities, 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 handle the respective inquiry. This usually includes details such as name, contact information, and potentially further information provided to us that is necessary for appropriate processing. We use this data exclusively for the specified purpose of contact and communication; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).
Plug-ins and Embedded Functions and Content
We integrate functional and content elements into our online services that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). This can be, for example, 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 user's IP address, since they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content or functional elements. We strive to only use content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous 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 times, and other details about the use of our online services, but can 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 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 refer you to the information on the use of cookies in this privacy policy.
- Types of processed data: Usage data (e.g., pages visited, interest in content, access times). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the details 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 can be stored on users' devices for a period of two years.).
- Legal bases: Consent (Art. 6 (1) (a) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing activities, procedures, and services:
- Integration of third-party software, scripts, or frameworks (e.g., jQuery): We integrate software into our online services that we retrieve from servers of other providers (e.g., functional libraries that we use for the presentation or user-friendliness of our online services). In doing so, the respective providers collect the user's IP address and can process it for the purpose of transmitting the software to the user's browser, as well as for security purposes, evaluation, and optimization of their services. Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
- Google Fonts (retrieved from Google server): Acquisition of fonts (and symbols) for the purpose of a technically secure, maintenance-free, and efficient use of fonts and symbols with regard to currency and loading times, their uniform presentation, and consideration of possible license restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) necessary for the provision of fonts depending on the devices used and the technical environment are transmitted. This data can be processed on a server of the font provider in the US. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertisements; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://developers.google.com/fonts/faq/privacy?hl=en.
Privacy Information for Whistleblowers
Our goal is to provide an uncomplicated and confidential way to report misconduct in our organization. We take every report seriously and investigate it carefully to meet legal requirements and ensure transparency.
Legal bases (Germany): Insofar as we process data to fulfill our legal obligations under the Whistleblower Protection Act (Hinweisgeberschutzgesetz – HinSchG), the legal basis for processing is Art. 6 (1) (c) GDPR and, in the case of special categories of personal data, Art. 9 (2) (g) GDPR, § 22 BDSG, in each case in conjunction with § 10 HinSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the performance of its legal tasks and, in the case of using the data collected in the reporting procedure, taking further follow-up measures such as investigations, disciplinary proceedings, or passing them on to competent authorities.
Types of processed data: In the context of receiving and processing reports, as well as in the subsequent whistleblower procedure, we can collect various data. This includes in particular the data provided by a whistleblower, such as: name, contact details and location of the reporting person, names and data on potential witnesses or persons affected by the report, names and data on the persons against whom the report is directed, data about the suspected misconduct, as well as other relevant details if communicated by the whistleblower or determined in the course of the investigation.
Special categories of personal data: It may happen that we collect special types of personal data in the course of our activities, in particular if communicated by a whistleblower. This includes: health-related data of a person, data on racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic, biometric or sexual data, provided that these are absolutely necessary for the investigation of the report.
Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called 'Incognito Mode' of your browser. How to open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.
When accessing our website in normal mode, your browser automatically sends connection data (e.g., your IP address) to our server. Switching to private mode prevents local browser data (such as history and cookies) from being stored.
Providing names: You have the option to submit reports anonymously. Unless prohibited by national legislation, we recommend providing your name and contact details. This allows us to investigate the report more effectively and, if necessary, contact you directly. If you provide your name and contact details, your identity will be treated as strictly confidential and only disclosed to the persons responsible for the reporting office, unless statutory exceptions apply.
Providing data to third parties: Data related to the reports submitted will only be passed on to third parties under specific circumstances. This happens either a) if you have given us your explicit consent, or b) if there is a legal obligation to pass on the data. Potential third parties include public authorities, government, regulatory or tax authorities if the transfer is necessary to fulfill a legal or regulatory obligation. We may also instruct lawyers and other professional advisers in accordance with legal provisions. These are entitled to review suspected misconduct and take necessary measures after an investigation, such as initiating disciplinary or legal proceedings. In addition, carefully selected and monitored service providers may receive data for these purposes (for example, operators of a web-based reporting system). However, these service providers are contractually obliged to comply with applicable data protection regulations in the context of order data processing.
Data retention and deletion: Personal data is only processed for as long as necessary to fulfill the processing purposes described above. If this data is no longer required for the purposes mentioned, it will be deleted. In certain situations, documentation obligations may require a longer retention, for example during an ongoing investigation or court proceedings.
Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. The incoming reports are received and processed by persons authorized to do so and bound to confidentiality.
- Types of processed data: Master data (e.g., full name, home address, contact information, customer number); Employee data (information on employees and other persons in an employment relationship); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts, as well as related information, such as authorship). Usage data (e.g., pages visited, interest in content, access times).
- Data subjects: Employees (e.g., staff, applicants, temporary workers); Third parties. Whistleblowers.
- Purposes of processing: Whistleblower protection.
- Storage and deletion: Deletion in accordance with the details in the section "General Information on Data Storage and Deletion".
- Legal bases: Consent (Art. 6 (1) (a) GDPR); Legal obligation (Art. 6 (1) (c) GDPR). Legitimate interests (Art. 6 (1) (f) GDPR).
Changes and Updates
We ask you to inform yourself regularly about the content of our privacy policy. We adjust the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require cooperation on your part (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 details before contacting them.
Definitions of Terms
In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations, on the other hand, are intended primarily to aid understanding.
- Employees: Employees are defined as persons who are in an employment relationship, whether as staff, employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee established by an employment contract or agreement. Employee data are all data related to the employment relationship and processed for its establishment, performance, or termination.
- Master data: Data required for the establishment, content design, or amendment of a contractual relationship (e.g., names, addresses).
- Contact data: Details that enable contact to be made (e.g., email address, telephone number).
- Content data: Content of entries or notifications (e.g., text entries, form contents).
- Usage data: Data about the use of our online services (e.g., visited websites, interest in content, access times).
- Meta, communication, and process data: Technical data generated in the context of electronic communication (e.g., IP addresses, device information, log files).
- Personal data: Any information relating to an identified or identifiable natural person.
- Controller: The natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: Any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means (e.g., collection, storage, adaptation, retrieval, erasure).
Created with free Datenschutz-Generator.de by Dr. Thomas Schwenke
