Privacy Policy

The controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection provisions is:

Twelvebytwelve GmbH House of Music Revaler Str. 99, Halle 20 10245 Berlin Germany

Email: contact@twlvxtwlv.com www.twlvxtwlv.com

1. Scope of the processing of personal data

As a matter of principle, we only process our users' personal data to the extent necessary to provide a functional website and our content and services. The processing of our users' personal data regularly takes place only with the user's consent. An exception applies in cases where prior consent cannot be obtained for practical reasons and the processing of the data is required by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, § 25 (1) of the German Act on Data Protection and Privacy in Telecommunications and Digital Services (TDDDG) in conjunction with Art. 6 (1) lit. a GDPR serves as the legal basis.

For the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 (1) sentence 1 lit. b GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual measures.

Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 (1) sentence 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Art. 6 (1) sentence 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the aforementioned interest, § 25 (2) TDDDG in conjunction with Art. 6 (1) lit. f GDPR serves as the legal basis for the processing.

3. Data erasure and storage period

The personal data of the data subject will be erased or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. Data will also be blocked or erased when a storage period prescribed by the aforementioned norms expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. Right of access

You may request confirmation from the controller as to whether personal data concerning you is being processed by the controller.

If such processing is taking place, you may request the following information from the controller:

• the purposes for which the personal data is processed;
• the categories of personal data being processed;
• the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
• the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
• the existence of a right to lodge a complaint with a supervisory authority;
• all available information on the origin of the data if the personal data was not collected from the data subject;
• the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and — at least in these cases — meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The controller must carry out the rectification without undue delay.

3. Right to restriction of processing

You may request the restriction of the processing of personal data concerning you under the following conditions:

• if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
• the processing is unlawful and you oppose the erasure of the personal data and instead request the restriction of the use of the personal data;
• the controller no longer needs the personal data for the purposes of the processing, but you need it for the establishment, exercise or defence of legal claims, or
• if you have objected to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

Where the processing of personal data concerning you has been restricted, such data may — apart from its storage — only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the restriction of processing has been imposed in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay, if one of the following reasons applies:

• The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
• You withdraw your consent on which the processing was based pursuant to Art. 6 (1) sentence 1 lit. a or Art. 9 (2) lit. a GDPR and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
• The personal data concerning you has been processed unlawfully.
• The erasure of the personal data concerning you is necessary to fulfil a legal obligation under Union or Member State law to which the controller is subject.
• The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

b) Information to third parties

Where the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you, as the data subject, have requested the erasure by such controllers of any links to, or copies or replications of, that personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health pursuant to Art. 9 (2) lit. h and i and Art. 9 (3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
• for the establishment, exercise or defence of legal claims.

5. Right to notification

If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you has been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.

6. Right to data portability

You have the right to receive the personal data concerning you which you have provided to the controller in a structured, commonly used and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, where

• the processing is based on consent pursuant to § 25 (1) TDDDG in conjunction with Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) sentence 1 lit. b GDPR and
• the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. The freedoms and rights of other persons must not be adversely affected by this.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 (1) sentence 1 lit. e or f GDPR; this also applies to profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Where 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 marketing; this also applies to profiling insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

In connection with the use of information society services — notwithstanding Directive 2002/58/EC — you have the option of exercising your right to object by automated means using technical specifications.

8. Right to withdraw the declaration of consent under data protection law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the point of withdrawal.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

• is necessary for entering into, or the performance of, a contract between you and the controller,
• is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
• is based on your explicit consent.

However, these decisions must not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) lit. a or b GDPR applies and suitable measures have been taken to protect your rights and freedoms and legitimate interests.

With regard to the cases referred to in 1. and 3., the controller shall take suitable measures to safeguard your rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express your own point of view and to contest the decision.

10. 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.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing device.

The following data is collected:

• Information about the browser type and version used
• The user's operating system
• The user's IP address
• Date and time of access
• Websites from which the user's system reaches our website

This data is stored in the logfiles of our system. This data is not stored together with other personal data of the user.

2. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's device. For this purpose, the user's IP address must remain stored for the duration of the session.

Storage in logfiles takes place to ensure the functionality of the website. In addition, the data serves to optimise the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.

These purposes also constitute our legitimate interest in the data processing pursuant to § 25 (2) TDDDG in conjunction with Art. 6 (1) lit. f GDPR.

3. Legal basis for data processing

The legal basis for the temporary storage of the data and the logfiles is § 25 (2) TDDDG in conjunction with Art. 6 (1) lit. f GDPR.

4. Duration of storage

The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. In the case of data collected for the provision of the website, this is the case when the respective session has ended.

In the case of data stored in logfiles, this is the case after no more than seven days. Storage beyond this period is possible. In this case, the users' IP addresses are erased or anonymised so that it is no longer possible to attribute them to the accessing client.

5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in logfiles is strictly necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system.

This website does not use cookies. Neither technically necessary cookies nor analytics, tracking or marketing cookies are set; comparable technologies (e.g. local storage) are not used either. The language selection is made exclusively via the URL (e.g. /en) and does not require any information to be stored on your device.

As no cookies are set and no information on your terminal equipment is accessed, no consent pursuant to § 25 (1) TDDDG is required. For this reason, no cookie banner or consent tool is used.

1. Description and scope of data processing

It is possible to contact us via the email address provided on our website. In this case, the user's personal data transmitted with the email is stored.

The data is used exclusively for processing the conversation.

2. Purpose of data processing

In the case of contact by email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 (1) lit. a GDPR if the user has given consent.

The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 (1) lit. f GDPR. If the email contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

4. Duration of storage

The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation has ended when it can be inferred from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be erased after a period of no more than seven days.

5. Possibility of objection and removal

The user has the option of withdrawing their consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of the contact will be erased in this case.

We maintain company pages on social networks. We are represented on the following social networks:

Instagram

Instagram, Part of Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

On our company page we provide information and offer Instagram users the opportunity to communicate. If you carry out an action on our Instagram company page (e.g. comments, posts, likes etc.), you may make personal data (e.g. your real name or a photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, the company jointly responsible for the Twelvebytwelve GmbH company page, we cannot make any binding statements about the purpose and scope of the processing of your data.

Our company page on social networks is used for communication and the exchange of information with (potential) customers, in particular for information about products and services.

Every user is free to publish personal data through their activities.

The legal basis for the data processing is Art. 6 (1) sentence 1 lit. a GDPR.

The data generated by the company page is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect in the context of your use of our Instagram company page and assert your data subject rights set out under III. of this privacy policy. To do so, send us an informal email to contact@twlvxtwlv.com. Further information on the processing of your personal data by Instagram and the corresponding objection options can be found here: https://help.instagram.com/519522125107875

X (formerly Twitter)

Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland

On our company page we provide information and offer users the opportunity to communicate. If you carry out an action on our company page (e.g. comments, posts, likes etc.), you may make personal data (e.g. your real name or a photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by the company jointly responsible for the Twelvebytwelve GmbH company page, we cannot make any binding statements about the purpose and scope of the processing of your data.

Our company page on social networks is used for communication and the exchange of information with (potential) customers, in particular for information about products and services.

Every user is free to publish personal data through their activities.

The legal basis for the data processing is Art. 6 (1) sentence 1 lit. a GDPR.

The data generated by the company page is not stored in our own systems.

You can object at any time to the processing of your personal data that we collect in the context of your use of our company page and assert your data subject rights set out under III. of this privacy policy. To do so, send us an informal email to contact@twlvxtwlv.com. Further information on the processing of your personal data and the corresponding objection options can be found here: https://twitter.com/en/privacy

1. Scope of data processing

We use the option of company pages on professional networks. We maintain a company page on the following professional networks:

LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

On our page we provide information and offer users the opportunity to communicate. The company page is used for job applications, information/PR and active sourcing.

We have no information on the processing of your personal data by the companies jointly responsible for the company page. Further information can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy

If you carry out an action on our company page (e.g. comments, posts, likes etc.), you may make personal data (e.g. your real name or a photo of your user profile) public.

2. Legal basis for data processing

The legal basis for the processing of your data in connection with the use of our company page is Art. 6 (1) sentence 1 lit. f GDPR.

3. Purpose of data processing

Our company page serves to inform users about our services. Every user is free to publish personal data through their activities.

4. Duration of storage

We store your activities and personal data published via our company page until you withdraw your consent. In addition, we comply with the statutory retention periods.

5. Possibility of objection and removal

You can object at any time to the processing of your personal data that we collect in the context of your use of our company page and assert your data subject rights set out under III. of this privacy policy. To do so, send us an informal email to the email address stated in this privacy policy.

Further information on objection and removal options can be found here: https://www.linkedin.com/legal/privacy-policy

The website is hosted on servers of a service provider commissioned by us. Our service provider is:

Vercel Inc. 440 N Barranca Avenue #4133 Covina, CA 91723 USA

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

• Browser type and browser version
• Operating system used
• Referrer URL
• Hostname of the accessing device
• Date and time of the server request
• IP address

This data is not merged with other data sources. This data is collected on the basis of Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website — the server log files must be collected for this purpose.

The website is delivered via the service provider's global content delivery network; the content is primarily delivered via servers in the European Union (Frankfurt am Main region). In the process, data may be transferred to servers of Vercel Inc. in the USA. The transfer is based on the adequacy decision of the European Commission on the EU-US Data Privacy Framework of 10 July 2023; Vercel Inc. is certified under the EU-US Data Privacy Framework. We have concluded a data processing agreement with the service provider, obliging the service provider to protect user data and not to pass it on to third parties.

Further information on the processing of data by Vercel can be found here: https://vercel.com/legal/privacy-policy

1. Description and scope of data processing

We use Vercel Web Analytics on our website, a web analytics service provided by Vercel Inc., 440 N Barranca Avenue #4133, Covina, CA 91723, USA. The collection takes place server-side and without cookies; no information is stored on or read from your device, and no cross-site tracking takes place. In particular, the following data is processed:

• pages visited (URL) and referrer URL
• browser type and browser version
• operating system and device type
• approximate geographic origin (country/region)
• date and time of access

The IP address is used exclusively to generate an anonymised identifier (hash) that changes daily and is not stored permanently. It is not possible to identify individual visitors or to merge the data with other personal data; the analysis takes place exclusively in aggregated form.

2. Purpose of data processing

The processing serves to measure the reach of our website and to analyse and optimise it.

3. Legal basis for data processing

As no cookies are set and no information on your terminal equipment is accessed, no consent pursuant to § 25 (1) TDDDG is required. The legal basis for the processing is Art. 6 (1) lit. f GDPR; our legitimate interest lies in the statistical analysis and optimisation of our online offering.

4. Duration of storage

The analysis is based on aggregated statistical data that does not contain any personal data. In the process, data may be transferred to servers of Vercel Inc. in the USA; the transfer is based on the adequacy decision of the European Commission on the EU-US Data Privacy Framework of 10 July 2023, under which Vercel Inc. is certified.

5. Possibility of objection and removal

You may object to the processing at any time on grounds relating to your particular situation and assert your data subject rights set out under III. of this privacy policy. To do so, send us an informal email to contact@twlvxtwlv.com.