1) Information about the collection of personal data and contact details of the controller

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about how we handle your personal data when you use our website. Personal data refers to all data that can be used to personally identify you.

1.2 The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Jan-Willem Wulff, Sowel, Lerchenstr. 28, 22767 Hamburg, Germany, Tel.: +49 4050719309, Email: info@sowel.eu. The controller for personal data is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.

1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the character string "https://" and the lock symbol in your browser bar.

2) Data collection when visiting our website

If you use our website for informational purposes only, i.e., if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

• Our visited website
• Date and time of access
• Amount of data sent in bytes
• Source/reference from which you came to the page
• Browser used
• Operating system used
• IP address used (if applicable: in anonymized form)

Processing is carried out in accordance with Art. 6 (1) (f) GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be shared or used for any other purpose. However, we reserve the right to subsequently review the server log files if there are concrete indications of illegal use.

3) Cookies

To make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your device and enable us or our partner companies (third-party cookies) to recognize your browser the next time you visit (persistent cookies). If cookies are set, they collect and process certain user information to an individual extent, such as browser and location data as well as IP address values. Persistent cookies are automatically deleted after a specified period of time, which can vary depending on the cookie.

In some cases, cookies are used to simplify the ordering process by saving settings (e.g., remembering the contents of a virtual shopping cart for a later visit to the website). If personal data is also processed through individual cookies implemented by us, the processing is carried out in accordance with Art. 6 (1) (b) GDPR either to execute the contract or in accordance with Art. 6 (1) (f) GDPR to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

We may work with advertising partners who help us make our website more interesting for you. For this purpose, cookies from partner companies will also be stored on your hard drive when you visit our website (third-party cookies). If we work with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case in the paragraphs below.

Please note that you can set your browser to inform you about the use of cookies and to decide individually whether to accept them or to reject cookies in certain cases or generally. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how to change your cookie settings. You can find these settings for each browser at the following links:

Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehne
Chrome: https://support.google.com/chrome/answer/95647?hl=de&hlrm=en
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note that if you do not accept cookies, the functionality of our website may be limited.

4) Contact

When you contact us (e.g. via contact form or email), personal data is collected. Which data is collected when you use a contact form can be seen in the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for establishing contact and the associated technical administration. The legal basis for processing the data is our legitimate interest in answering your request in accordance with Art. 6 (1) (f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR. Your data will be deleted after your request has been finally processed. This is the case if the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention periods to the contrary.

5) Data processing when opening a customer account and for contract processing

According to Art. 6 (1) (b) GDPR, personal data will continue to be collected and processed if you provide it to us to perform a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. You can delete your customer account at any time and can do so by sending a message to the above-mentioned address of the person responsible. We store and use the data you provide to process the contract. After the contract has been fully processed or your customer account has been deleted, your data will be blocked with regard to retention periods under tax and commercial law and deleted after these periods have expired, unless you have expressly consented to further use of your data or we have reserved the right to further use of the data that is permitted by law, about which we will inform you accordingly below.

6) Use of your data for direct marketing

6.1 Registration for our email newsletter

If you subscribe to our email newsletter, we will regularly send you information about our offers. The only mandatory information required to receive the newsletter is your email address. Providing any other data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure to send the newsletter. This means that we will only send you an email newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation email asking you to confirm that you wish to receive future newsletters by clicking on a corresponding link.

By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6 (1) (a) GDPR. When you register for the newsletter, we save your IP address entered by your Internet service provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your email address at a later date. The data we collect when you register for the newsletter will be used exclusively for the purposes of advertising via the newsletter. You can unsubscribe from the newsletter at any time using the link provided for this purpose in the newsletter or by sending a corresponding message to the person responsible named above. After unsubscribing, your email address will be immediately deleted from our newsletter distribution list unless you have expressly consented to further use of your data or we reserve the right to use the data in any other way that is permitted by law and about which we inform you in this declaration.

6.2 Sending the email newsletter to existing customers

If you provided us with your email address when purchasing goods or services, we reserve the right to regularly send you offers for goods or services from our range that are similar to those you have already purchased. According to Section 7 (3) of the Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. Data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 (1) (f) GDPR. If you initially objected to the use of your email address for this purpose, we will not send you any emails. You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with future effect by notifying the person responsible named at the beginning. You will only incur transmission costs according to the basic rates. Upon receipt of your objection, the use of your email address for advertising purposes will be stopped immediately.

6.3 Newsletter dispatch via MailChimp
Our email newsletter is sent via the technical service provider The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (http://www.mailchimp.com/), to whom we pass on the data you provided when registering for the newsletter. This transfer takes place in accordance with Art. 6 (1) (f) GDPR and serves our legitimate interest in using an effective, secure, and user-friendly newsletter system. Please note that your data is generally transferred to a MailChimp server in the USA and stored there.
MailChimp uses this information to send and statistically evaluate the newsletter on our behalf. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. This makes it possible to determine whether a newsletter message has been opened and which links have been clicked. MailChimp uses web beacons to automatically create general, non-personal statistics on the response behavior to newsletter campaigns. Based on our legitimate interest in the statistical evaluation of newsletter campaigns to optimize advertising communication and better target recipient interests, the web beacons also collect and use data from the respective newsletter recipient (email address, time of retrieval, IP address, browser type, and operating system) in accordance with Art. 6 (1) (f) GDPR. This data allows individual conclusions to be drawn about the newsletter recipient and is processed by Mailchimp to automatically create statistics that show whether a specific recipient has opened a newsletter message.
If you wish to deactivate data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
MailChimp may also use this data itself, in accordance with Art. 6 (1) (f) GDPR, based on its own legitimate interest in tailoring and optimizing the service to meet customer needs, as well as for market research purposes, for example, to determine which countries the recipients come from. However, MailChimp does not use the data of our newsletter recipients to contact them directly or to share it with third parties.
To protect your data in the USA, we have entered into a data processing agreement with MailChimp based on the European Commission's standard contractual clauses to enable the transfer of your personal data to MailChimp. This data processing agreement can be viewed at the following internet address: https://mailchimp.com/legal/forms/data-processing-agreement
MailChimp is also certified under the US-European data protection agreement “Privacy Shield” and is therefore committed to complying with EU data protection regulations.
You can view MailChimp’s privacy policy here: https://mailchimp.com/legal/privacy/

7) Data processing for order processing

7.1 The personal data we collect will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment details to the commissioned credit institution as part of the payment processing, insofar as this is necessary for the payment processing. If payment service providers are used, we will explicitly inform you of this below. The legal basis for the transfer of data is Art. 6 (1) (b) GDPR.

7.2 Use of special service providers for order processing and execution

- SendCloud
Shipping is carried out via the shipping portal "SendCloud" (SendCloud GmbH, Kanalstr. 10, 80538 Munich). In accordance with Art. 6 (1) (b) GDPR, we will only share your data with SendCloud for the purpose of processing your online order. Data will only be shared if this is actually necessary for processing. Details on SendCloud's data protection policy can be found on the SendCloud website at www.sendcloud.de/datenschutz/.

7.3 Use of payment service providers (payment services)

- Amazon Pay
If you select the "Amazon Pay" payment method, payment processing will be carried out by the payment service provider Amazon Payments Europe sca, 5 Rue Plaetis, L-2338 Luxembourg (hereinafter: "Amazon Payments"), to whom we will forward the information you provided during the ordering process, along with information about your order, in accordance with Art. 6 (1) (b) GDPR. Your data will be forwarded exclusively for the purpose of payment processing with the payment service provider Amazon Payments and only to the extent necessary for this purpose. You can find further information about Amazon Payments' privacy policy at the following internet address: https://pay.amazon.com/de/help/201751600
- Paypal
When paying via PayPal, credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal, we will transfer your payment data to PayPal (Europe) Sarl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal") as part of the payment processing. This transfer takes place in accordance with Art. 6 (1) (b) GDPR and only to the extent necessary for payment processing.
PayPal reserves the right to conduct a credit check for payment methods such as credit card via PayPal, direct debit via PayPal, or – if offered – "purchase on account" or "installment payment" via PayPal. For this purpose, your payment data may be passed on to credit agencies in accordance with Art. 6 (1) (f) GDPR based on PayPal's legitimate interest in determining your ability to pay. PayPal uses the result of the credit check regarding the statistical probability of default to decide whether to provide the respective payment method. The credit check may contain probability values ​​(so-called score values). To the extent that score values ​​are included in the result of the credit check, they are based on a scientifically recognized mathematical-statistical procedure. Address data, among other things, is used to calculate the score values. For further information on data protection, including information on the credit agencies used, please refer to PayPal's privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.

8) Use of social media: videos

Use of Vimeo videos

Our website contains plug-ins from the video portal Vimeo, operated by Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA. When you access a page on our website that contains such a plug-in, your browser establishes a direct connection to Vimeo's servers. Vimeo transmits the content of the plug-in directly to your browser and integrates it into the page. Through this integration, Vimeo receives the information that your browser has accessed the corresponding page on our website, even if you do not have a Vimeo account or are not currently logged in to Vimeo. This information (including your IP address) is transmitted from your browser directly to a Vimeo server in the USA and stored there.
If you are logged in to Vimeo, Vimeo can directly associate your visit to our website with your Vimeo account. If you interact with the plugins (e.g., by clicking the start button of a video), this information is also transmitted directly to a Vimeo server and stored there.

The data processing operations described are carried out in accordance with Art. 6 (1) (f) GDPR on the basis of Vimeo’s legitimate interest in market research and the needs-based design of the service.

If you do not want Vimeo to directly assign the data collected via our website to your Vimeo account, you must log out of Vimeo before visiting our website.

For information on the purpose and scope of data collection and the further processing and use of data by Vimeo, as well as your rights and setting options for protecting your privacy, please refer to Vimeo's privacy policy: https://vimeo.com/privacy

Vimeo, Inc., based in the USA, is certified under the US-European data protection agreement "Privacy Shield," which guarantees compliance with the data protection level applicable in the EU. A current certificate can be viewed here: https://www.privacyshield.gov/list

For videos from Vimeo that are embedded on our site, the tracking tool Google Analytics from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, is automatically integrated. This is Vimeo's own tracking function, which we have no access to and which we cannot influence. Google Analytics uses so-called "cookies" for tracking purposes. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website is usually transferred to a Google server and stored there; in this case, the data may also be transferred to the servers of Google LLC in the USA.

In the event that personal data is transferred to Google LLC, based in the USA, Google LLC has certified itself for the US-European data protection agreement "Privacy Shield," which guarantees compliance with the data protection level applicable in the EU. A current certificate can be viewed here: https://www.privacyshield.gov/list

This processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of Vimeo’s legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.

9) Web analysis services

Google (Universal) Analytics

Google Universal Analytics with demographic characteristics
This website uses Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your shortened IP address) is typically transferred to a Google server and stored there. This may also include transmission to Google LLC servers in the USA.
This website uses Google Analytics exclusively with the extension "_anonymizeIp()", which ensures that the IP address is anonymized by shortening it and prevents it from being directly linked to a person. This extension shortens your IP address beforehand within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google LLC server in the USA and shortened there. In these exceptional cases, this processing is carried out in accordance with Art. 6 (1) (f) GDPR on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.
On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide us with other services related to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.
You can prevent cookies from being saved by selecting the appropriate settings in your browser; however, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=de
As an alternative to the browser plug-in or within browsers on mobile devices, please click on the following link to set an opt-out cookie that will prevent Google Analytics from collecting data on this website in the future (this opt-out cookie only works in this browser and only for this domain; if you delete your cookies in this browser, you must click this link again): Deactivate Google Analytics
In the event that personal data is transferred to Google LLC, based in the USA, Google LLC has certified itself for the US-European data protection agreement "Privacy Shield," which guarantees compliance with the data protection level applicable in the EU. A current certificate can be viewed here: https://www.privacyshield.gov/list
This website also uses Google Analytics for cross-device analysis of visitor traffic, which is performed using a user ID. When a page is accessed for the first time, the user is assigned a unique, permanent, and anonymized ID that is used across all devices. This makes it possible to assign interaction data from different devices and sessions to a single user. The user ID does not contain any personal data and does not transmit such data to Google.
You can object to the collection and storage of data via your user ID at any time with future effect. To do so, you must deactivate Google Analytics on all systems you use, for example, in another browser or on your mobile device.
This website also uses the "demographics" feature of Google Analytics. This allows reports to be created that contain information about demographic data such as the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google, the Google Display Network, and visitor data from third parties. You can deactivate this feature at any time via the ad settings in your Google Account or generally prohibit the collection of your data by Google Analytics, as shown below.
You can deactivate this using a browser plug-in from Google (https://tools.google.com/dlpage/gaoptout?hl=de). Alternatively to the browser plug-in, or within browsers on mobile devices, please click on the following link to set an opt-out cookie that will prevent Google Analytics from collecting data on this website in the future (this opt-out cookie only works in this browser and only for this domain; if you delete your cookies in this browser, you must click this link again): Deactivate Google Analytics
Further information on Google (Universal) Analytics can be found here: https://support.google.com/analytics/answer/2838718?hl=de&ref_topic=6010376

10) Retargeting/ Remarketing/ Referral Advertising

Facebook Custom Audience via the pixel process
This website uses the "Facebook Pixel" of Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"). If you give your explicit consent, this allows us to track user behavior after they have seen or clicked on a Facebook ad. This process is used to evaluate the effectiveness of Facebook ads for statistical and market research purposes and can help optimize future advertising campaigns.
The data collected is anonymous to us and therefore does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to place advertisements on and outside of Facebook. Furthermore, a cookie may be stored on your computer for these purposes. This processing only takes place with the express consent of Art. 6 (1) (a) GDPR.
Consent to the use of the Facebook pixel may only be given by users older than 13. If you are younger, we ask you to ask your legal guardian for permission.
Facebook Inc., based in the USA, is certified for the US-European data protection agreement “Privacy Shield”, which guarantees compliance with the data protection level applicable in the EU.
To disable the use of cookies on your computer, you can set your Internet browser so that no more cookies can be stored on your computer in the future or so that any cookies already stored are deleted. However, disabling all cookies may result in some functions on our website no longer being able to function. You can also disable the use of cookies by third parties such as Facebook on the following Digital Advertising Alliance website: https://www.aboutads.info/choices/

11) Tools and Other

Google Maps

Our website uses Google Maps (API) provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Maps is a web service for displaying interactive maps to visually present geographical information. Using this service will show you our location and make it easier to find us.

As soon as you access the subpages in which the Google Maps map is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers and stored there. This may also involve transmission to the servers of Google LLC in the USA. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data is assigned directly to your account. If you do not wish to be assigned to your Google profile, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. The collection, storage and evaluation are carried out in accordance with Art. 6 (1) (f) GDPR on the basis of Google's legitimate interests in the display of personalized advertising, market research and/or the needs-based design of Google websites. You have the right to object to the creation of these user profiles; to exercise this right you must contact Google.

In the event that personal data is transferred to Google LLC, based in the USA, Google LLC has certified itself for the US-European data protection agreement "Privacy Shield," which guarantees compliance with the data protection level applicable in the EU. A current certificate can be viewed here: https://www.privacyshield.gov/list

If you do not agree to the future transmission of your data to Google when using Google Maps, you can also completely deactivate the Google Maps web service by disabling JavaScript in your browser. Google Maps, and thus the map display on this website, will then not be available.

You can view Google's terms of use at https://www.google.de/intl/de/policies/terms/regional.html, and the additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html
Detailed information on data protection in connection with the use of Google Maps can be found on the Google website (“Google Privacy Policy”): https://www.google.de/intl/de/policies/privacy/

12) Rights of the data subject

12.1 The applicable data protection law grants you comprehensive rights as a data subject (rights of information and intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we will inform you below:

• Right to information in accordance with Art. 15 GDPR: In particular, you have the right to information about your personal data processed by us, the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom your data have been or will be disclosed, the planned storage period or the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it was not collected from you by us, the existence of automated decision-making including profiling and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing concerning you, as well as your right to information about the guarantees in accordance with Art. 46 GDPR when your data is transferred to third countries;
• Right to rectification in accordance with Art. 16 GDPR: You have the right to have any incorrect data concerning you rectified without delay and/or to have any incomplete data stored by us completed;
• Right to erasure pursuant to Art. 17 GDPR: You have the right to request the erasure of your personal data if the requirements of Art. 17 (1) GDPR are met. However, this right does not apply if processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise, or defend legal claims.
• Right to restriction of processing in accordance with Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you contest, is being verified, if you refuse to delete your data due to inadmissible data processing and instead request the restriction of the processing of your data, if you need your data to assert, exercise or defend legal claims after we no longer need this data after the purpose has been achieved or if you have lodged an objection for reasons related to your particular situation, as long as it has not yet been determined whether our legitimate reasons outweigh yours;
• Right to information pursuant to Art. 19 GDPR: If you have asserted your right to rectification, erasure, or restriction of processing vis-à-vis the controller, the controller is obligated to inform all recipients to whom the personal data concerning you was disclosed of this rectification, erasure, or restriction of processing, unless doing so proves impossible or involves disproportionate effort. You have the right to be informed about these recipients.
• Right to data portability pursuant to Art. 20 GDPR: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transmitted to another controller, where technically feasible;
• Right to revoke consent granted in accordance with Art. 7 (3) GDPR: You have the right to revoke your consent to the processing of data at any time with future effect. In the event of revocation, we will delete the data in question immediately, unless further processing can be based on a legal basis for processing without consent. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent up to the time of revocation;
• Right to lodge a complaint pursuant to Art. 77 GDPR: If you believe that the processing of personal data concerning you violates the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or place of the alleged infringement, without prejudice to any other administrative or judicial remedy.

12.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR OVERRIDING LEGITIMATE INTEREST AS PART OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH FUTURE EFFECT FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.
If you exercise your right to object, we will stop processing the data in question. However, we reserve the right to continue processing if we can demonstrate compelling legitimate grounds for the processing that override your interests, fundamental rights, and freedoms, or if the processing serves to assert, exercise, or defend legal claims.

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes. You can exercise your right of objection as described above.

IF YOU EXERCISE YOUR RIGHT OF OBJECTION, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

13) Duration of storage of personal data

The duration of storage of personal data is determined by the respective statutory retention period (e.g., retention periods under commercial and tax law). After expiration of this period, the corresponding data will be routinely deleted unless it is no longer required for the fulfillment or initiation of a contract and/or we no longer have a legitimate interest in continued storage.