Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find their contact details in the section “Information about the Responsible Entity” in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may, for example, include data you enter into a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This primarily includes technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the data provided will also be processed for contract offers, orders, or other inquiries.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipients, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. Additionally, you have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this or any other questions about data protection.

Analytics Tools and Third-Party Tools

When visiting this website, your surfing behavior may be statistically evaluated. This is primarily done using so-called analytics programs.

Detailed information about these analytics programs can be found in the following privacy policy.

2. Hosting

We host the content of our website with the following providers:

IONOS

The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter referred to as IONOS). When you visit our website, IONOS collects various log files, including your IP addresses. For details, please refer to IONOS’s privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.

The use of IONOS is based on Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring the most reliable presentation of our website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the aforementioned service. This is a contract required by data protection law, which ensures that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

External Hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, metadata and communication data, contract data, contact details, names, website accesses, and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfill their performance obligations and will follow our instructions regarding this data.

We use the following host(s):

HOSTINGER operations, UAB
Švitrigailos str. 34, Vilnius 03230 Lithuania
Phone: +37064503378
Email: domains@hostinger.com

Data Processing Agreement

3. General Information and Mandatory Information

Data Protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We point out that data transmission over the internet (e.g., communication via email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information about the Responsible Entity

The responsible entity for data processing on this website is:

xpand Deutschland GmbH
Ernst-Penzoldt-Weg 9
91080 Spardorf

Phone: 0821/21700080
Email: office@xpand.pro

The responsible entity is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, email addresses, etc.).

Storage Duration

Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial retention periods); in the latter case, deletion will occur after these reasons no longer apply.

General Information on the Legal Bases for Data Processing on This Website

If you have consented to data processing, we process your personal data based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data under Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), data processing is additionally based on § 25(1) TDDDG. Consent can be revoked at any time. If your data is required for contract fulfillment or to carry out pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR. Furthermore, we process your data if it is necessary to fulfill a legal obligation based on Art. 6(1)(c) GDPR. Data processing may also be based on our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the applicable legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Data Protection Officer

We have appointed a data protection officer.

Ricardo Wiedenbrüg
Ernst-Penzoldt-Weg 9
91080 Spardorf

Phone: +49 (0) 821 21700080
Email: datenschutz@xpand.pro

Information on Data Transfer to Third Countries with Inadequate Data Protection and to US Companies Not Certified Under DPF

We use, among other things, tools from companies based in third countries with inadequate data protection as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to these countries and processed there. We point out that no level of data protection comparable to that of the EU can be guaranteed in third countries with inadequate data protection.

We note that the USA, as a secure third country, generally has a level of data protection comparable to the EU. Data transfer to the USA is permissible if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has suitable additional safeguards. Information on transfers to third countries, including data recipients, can be found in this privacy policy.

Recipients of Personal Data

In the course of our business activities, we collaborate with various external entities. This sometimes requires the transfer of personal data to these external entities. We only transfer personal data to external entities if this is necessary for contract fulfillment, if we are legally obligated to do so (e.g., transferring data to tax authorities), if we have a legitimate interest under Art. 6(1)(f) GDPR in the transfer, or if another legal basis permits the data transfer. When using data processors, we only transfer personal data of our customers based on a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can revoke consent you have already given at any time. The legality of the data processing carried out prior to the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS, OR THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING PURPOSES; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, place of work, or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically based on your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Information, Correction, and Deletion

Within the framework of applicable legal provisions, you have the right to free information about your stored personal data, its origin, recipients, and the purpose of data processing at any time, and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this or any further questions about personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. During the verification period, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have objected pursuant to Art. 21(1) GDPR, a balancing of your and our interests must be carried out. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the assertion, exercise, or defense of legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.

SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Encrypted Payment Transactions on This Website

If, after concluding a fee-based contract, there is an obligation to provide us with your payment details (e.g., account number for direct debit authorization), this data is required for payment processing.

Payment transactions via common payment methods (Visa/MasterCard, direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

With encrypted communication, your payment data that you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Cookies

Our websites use so-called “cookies.” Cookies are small data packets that do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted after your visit ends. Persistent cookies remain stored on your device until you delete them yourself or an automatic deletion occurs through your web browser.

Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions you desire (e.g., for the shopping cart function), or to optimize the website (e.g., cookies to measure the web audience) (necessary cookies) are stored based on Art. 6(1)(f) GDPR unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively based on this consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent can be revoked at any time.

You can set your browser to inform you about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

You can find out which cookies and services are used on this website in this privacy policy.

Consent with Borlabs Cookie

Our website uses Borlabs Cookie consent technology to obtain your consent for the storage of certain cookies in your browser or for the use of certain technologies and to document this in a data protection-compliant manner. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, which stores the consents you have given or the revocation of these consents. This data is not shared with the provider of Borlabs Cookie.

The collected data is stored until you request us to delete it, delete the Borlabs cookie yourself, or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on the data processing of Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

The use of Borlabs Cookie consent technology is carried out to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.

Contact Form

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

The processing of this data is based on Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your inquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Inquiry by Email, Phone, or Fax

If you contact us by email, phone, or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of handling your request. We do not share this data without your consent.

The data you send to us via contact inquiries will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Registration on This Website

You can register on this website to use additional functions on the site. We use the data entered for this purpose only for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.

For important changes, such as changes to the scope of the offer or technically necessary changes, we use the email address provided during registration to inform you in this way.

The processing of the data entered during registration is carried out for the purpose of implementing the user relationship established by the registration and, if necessary, for initiating further contracts (Art. 6(1)(b) GDPR).

The data collected during registration will be stored by us as long as you are registered on this website and will then be deleted. Statutory retention periods remain unaffected.

Processing of Data in AI Services

Our platform xpandAI provides you with access to various AI services via standardized APIs. In doing so, we process personal data in our own systems in full compliance with the provisions of the GDPR. The following information applies if you use our AI services:

External API access to language models:

We provide access to external language models offered by third-party providers (e.g., OpenAI, Anthropic). Some of these models are secured through data processing agreements (DPAs) and are operated on servers located in Germany or the EU. For other models, no such agreement exists, and data processing may take place in third countries. In such cases, we provide transparent information about the scope and risks of the data processing.

Use of system prompts and vector databases:

Within our assistant solutions, we use so-called system prompts to configure requests to the underlying AI models. These prompts serve as a preliminary instruction and do not modify the models themselves. Optionally, company data can be integrated via a vector database for use within the assistants. Data is processed exclusively for the purpose of providing the agreed services. Providers such as OpenAI are covered by appropriate data processing agreements.

Transparency obligations under the EU AI Act:

xpandAI fulfills the transparency obligations of the EU AI Act by clearly labeling all AI-generated content. Users are informed whenever they interact with an AI system. There is no guarantee regarding the factual accuracy or legal applicability of the generated content. Final review and use are the responsibility of the user.

Risk management and feedback:

We document internal measures for risk prevention and monitoring in accordance with the EU AI Act. If problematic or discriminatory AI outputs occur, users can contact us via support@xpand.pro or the platform's feedback function. xpandAI reviews such reports and initiates appropriate actions if necessary.

Responsibilities:

xpandAI does not train its own AI models but provides access to existing external systems. The primary data protection responsibility for the respective model processing lies with the model provider—unless a data processing agreement is in place. We provide transparent information on our website about the systems used and their technical and data protection characteristics.

6. eCommerce and Payment Providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data to establish, structure, and modify our contractual relationships. We collect, process, and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill for it. The legal basis for this is Art. 6(1)(b) GDPR.

The collected customer data will be deleted after completion of the order or termination of the business relationship and the expiry of any applicable statutory retention periods. Statutory retention periods remain unaffected.

5. Plugins and Tools

SolidWP

We have integrated SolidWP on this website. The provider is iThemes Media LLC, 1720 South Kelly Avenue Edmond, OK 73013, USA (hereinafter referred to as “SolidWP”).

SolidWP is used to protect our website from unwanted access or malicious cyberattacks. For this purpose, SolidWP collects, among other things, your IP address, the time and source of login attempts, and log data (e.g., the browser used). SolidWP is installed locally on our servers.

The use of SolidWP is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its website from cyberattacks as effectively as possible. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

ChatGPT

We use ChatGPT for our customer communication. The provider is OpenAI, 3180 18th St, San Francisco, CA 94110, USA, https://openai.com.

When you start a conversation with us via our website and ChatGPT is activated, your inputs, including metadata, are transmitted to ChatGPT’s servers and processed there to generate an appropriate response.

We have configured ChatGPT so that the personal data entered is not used to train ChatGPT’s algorithm.

The use of ChatGPT is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in efficient customer communication using modern technical solutions. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

For more information, see: https://openai.com/policies/privacy-policy.

Data Processing Agreement

6. eCommerce and Payment Providers

Processing of Customer and Contract Data

Data Transfer Upon Conclusion of a Contract for Services and Digital Content

We transfer personal data to third parties only if this is necessary within the scope of contract processing, for example, to the credit institution entrusted with payment processing.

No further transfer of data takes place or only if you have expressly consented to the transfer. Your data will not be passed on to third parties without your express consent, for example, for advertising purposes.

The basis for data processing is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual measures.

Payment Services

We integrate payment services from third-party companies on our website. When you make a purchase with us, your payment data (e.g., name, payment amount, bank details, credit card number) is processed by the payment service provider for the purpose of payment processing. The respective contractual and data protection provisions of the respective providers apply to these transactions. The use of payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment process (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consents can be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.

For more details, please refer to Stripe’s privacy policy at the following link: https://stripe.com/de/privacy.