Privacy policy

  1. Introduction

With the following information, we would like to give you as a “data subject” an overview of the processing of your personal data by us and your rights under the data protection laws. In principle, it is possible to use our website without entering personal data. However, if you want to use special services of our enterprise via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent.

The processing of personal data, such as your name, address, or e-mail address, shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Passolution. By means of this privacy policy, we would like to inform you about the scope and purpose of the personal data we collect, use and process.

As the controller, we have implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by post.

2. Person responsible

The responsible party within the meaning of the DS-GVO is:

Passolution GmbH
Karl-Schiller-Strasse 5
51503 Rösrath

Represented by: Dennis Zimon, Daniel Henninger


3. Data Protection Officer

You can reach the data protection officer as follows:

Datenmeier GmbH & Co. KG
Geistwall 12 & 14
32312 Lübbecke

You can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.

4. Legal basis of processing

Art. 6 para. 1 lit. a DS-GVO (in conjunction with § 25 para. 1 TTDDG) serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose.

If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 (1) lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services.

If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c DS-GVO.

In rare cases, the processing of personal data might become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) (d) DS-GVO.

Finally, processing operations could be based on Art. 6(1)(f) DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 DS-GVO).

5. Transfer of data to third parties

We do not transfer your personal data to third parties for purposes other than those listed below.

We only pass on your personal data to third parties if:

you have given us your express consent in accordance with Art. 6 Para. 1 lit. a DS-GVO,
the disclosure is permissible in accordance with Art. 6 Para. 1 lit. f DS-GVO to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
in the event that a legal obligation exists for the disclosure in accordance with Art. 6 Para. 1 lit. c DS-GVO, as well as
this is legally permissible and necessary for the processing of contractual relationships with you according to Art. 6 para. 1 lit. b DS-GVO.
Within the scope of the processing operations described in this data protection declaration, personal data may be transferred to the USA. The USA does not have an adequate level of data protection (Schrems II – ECJ ruling of 16.07.2020, C-311/18). To protect your data, we have concluded commissioned processing agreements based on the European Commission’s standard contractual clauses. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Article 49 (1) a) of the GDPR may serve as the legal basis for the transfer to third countries. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Art. 45 DS-GVO.

6. Technology

6.1 SSL/TLS encryption

This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognise an encrypted connection by the fact that there is a “https://” instead of a “http://” in the address line of the browser and by the lock symbol in your browser line.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website

When you use our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect the data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information with each call-up of a page by you or by an automated system. This general data and information is stored in the server log files. The following data may be collected

the browser types and versions used
the operating system used by the accessing system
the website from which an accessing system arrives at our website (so-called referrer),
the sub-websites which are accessed via an accessing system on our website,
the date and time of an access to the website,
an Internet protocol address (IP address) and,
the internet service provider of the accessing system.
When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required in order to

to deliver the contents of our website correctly,
to optimise the contents of our website as well as the advertising for the same,
to ensure the long-term functionality of our IT systems and the technology of our website, and
to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Therefore, the data and information collected is, on the one hand, statistically evaluated by us and, on the other hand, it is analysed with the aim of increasing the data protection and data security of our enterprise so as to ultimately ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from any personal data provided by a data subject.

The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the purposes for data collection listed above.

The general provision and maintenance of our website is carried out with the support of an IT service provider acting on our behalf. Commissioned service provider:

Host Europe GmbH
Hansestrasse 111
51149 Cologne

6.3 Cloudflare (Content Delivery Network)

Our website uses functions from CloudFlare. The provider is CloudFlare, Inc. 665 3rd St. #200, San Francisco, CA 94107, USA.

CloudFlare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through CloudFlare’s network. CloudFlare is thus able to analyse the data traffic between users and our websites, for example, in order to detect and ward off attacks on our services. In addition, CloudFlare may store cookies on your computer for optimisation and analysis.

You can set your browser so that you are informed about the setting of cookies and only allow cookies 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. If cookies are deactivated, the functionality of this website may be limited.

We have concluded a corresponding agreement with Cloudflare on the basis of the German Data Protection Regulation (DS-GVO) for commissioned processing or in accordance with EU standard contractual clauses. Cloudflare collects statistical data about visits to this website. The access data includes: Name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider. Cloudflare uses the log data for statistical evaluations for the purpose of the operation, security and optimisation of the offer.

If you have consented to Cloudflare being used, the legal basis for the processing of personal data is Art. 6 (1) lit. a DS-GVO. The personal data will be kept for as long as it is necessary to fulfil the purpose of the processing. The data will be deleted as soon as they are no longer required to achieve the purpose.

The transfer of your personal data to the USA takes place on the basis of the standard contractual clauses.

For more information on CloudFlare, please visit:

7. Cookies

7.1 General information about cookies

We use cookies on our website. These are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.

Information is stored in the cookie that results in each case from the context of the specific end device used. However, this does not mean that we gain direct knowledge of your identity.

The use of cookies serves to make the use of our offer more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognised that you have already been to our site and which entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimisation. These cookies enable us to automatically recognise that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.

7.2 Legal basis for the use of cookies

The data processed by the cookies, which are required for the proper functioning of the website, are thus necessary to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) lit. f DS-GVO.

For all other cookies, it applies that you have given your consent to this within the meaning of Art. 6 (1) lit. a DS-GVO via our opt-in cookie banner.

8. Contents of our website

8.1 Registration as a user

You have the option of registering on our Profile Centre by providing personal data.

Which personal data is transmitted to us in the process is determined by the respective input mask used for registration. The personal data you enter is collected and stored exclusively for internal use by us and for our own purposes. We may arrange for it to be passed on to one or more order processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use attributable to us.

By registering on our website, the IP address assigned by your Internet service provider (ISP), the date and the time of registration are also stored. This data is stored because it is the only way to prevent misuse of our services and, if necessary, to enable the investigation of criminal offences. In this respect, the storage of this data is necessary for our protection. As a matter of principle, this data is not passed on to third parties. This does not apply if we are legally obliged to pass on the data or if the passing on of the data serves the purpose of criminal prosecution.

Your registration, with voluntary provision of personal data, also enables us to offer you content or services which, due to their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from our database.

Upon request, we will provide you at any time with information about which personal data is stored about you. Furthermore, we will correct or delete personal data at your request, insofar as this does not conflict with any legal obligations to retain data. A data protection officer named in this data protection declaration and all other employees are available to the data subject as contact persons in this context.

Your data is processed in the interest of convenient and simple use of our website. This constitutes a legitimate interest within the meaning of Art. 6 (1) f) of the Data Protection Act.

8.2 Contacting us / contact form

Personal data is collected when contacting us (e.g. via contact form or e-mail). Which data is collected when using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Art. 6 Para. 1 lit. f DS-GVO. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b DS-GVO. Your data will be deleted after final processing of your request; this is the case if it can be inferred from the circumstances that the matter in question has been conclusively clarified and the deletion does not conflict with any statutory retention obligations.

8.3 Services / Digital goods

We only transmit personal data to third parties if this is necessary within the framework of the contract processing, for example to the credit institution commissioned with the payment processing. To process orders, we use Zoho Forms from Zoho Corporation, 4141 Hacienda Drive Pleasanton, CA 94588, USA (“Zoho”). The terms of use and privacy policy of the provider can be found here and here respectively.

No further transmission of data will take place or only if you have expressly consented to the transmission. 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 para. 1 lit. b DS-GVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

9. Our activities in social networks

So that we can also communicate with you on social networks and inform you about our services, we are represented there with our own pages. If you visit one of our social media pages, we are jointly responsible for the processing operations triggered by this, within the meaning of Art. 26 DS-GVO, with the provider of the respective social media platform.

We are not the original provider of these pages, but merely use them within the scope of the possibilities offered to us by the respective providers.

As a precaution, we therefore point out that your data may also be processed outside the European Union or the European Economic Area. Use may therefore be associated with data protection risks for you, as it may be more difficult to protect your rights, e.g. to information, deletion, objection, etc., and the processing in the social networks often takes place directly for advertising purposes or for the analysis of user behaviour by the providers, without this being able to be influenced by us. If usage profiles are created by the provider, cookies are often used or the usage behaviour is assigned to your own member profile of the social networks.

The described processing of personal data is carried out in accordance with Art. 6 Para. 1 lit. f DS-GVO on the basis of our legitimate interest and the legitimate interest of the respective provider in order to be able to communicate with you in a timely manner or to inform you about our services. If you have to give your consent to data processing as a user with the respective providers, the legal basis refers to Art. 6 (1) lit. a DS-GVO in conjunction with Art. 7 DS-GVO. Art. 7 DS-GVO.

As we do not have access to the providers’ databases, we would like to point out that it is best to exercise your rights (e.g. to information, correction, deletion, etc.) directly with the respective provider. Further information on the processing of your data in the social networks and the possibility of exercising your right of objection or revocation (so-called opt-out) is listed below for the respective social network provider we use:

9.1 Facebook

(Co-) responsible for data processing in Europe:

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

Privacy Policy (Data Policy):

9.2 Instagram

(Co-) controller for data processing in Germany:

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

Privacy policy (data policy):

10. Web analytics

10.1 Google Analytics

On our websites, we use Google Analytics, a web analytics service provided by Google Ireland Limited (, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). In this context, pseudonymised usage profiles are created and cookies (see point “Cookies”) are used. The information generated by the cookie about your use of this website, such as

the browser type/version,
the operating system used,
the referrer URL (the previously visited page),
the host name of the accessing computer (IP address) and
time of the server request,
are transmitted to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of these Internet pages in line with requirements. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data. The IP addresses are anonymised so that an allocation is not possible (IP masking).

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

These processing operations will only be carried out if you have given your express consent in accordance with Art. 6 (1) lit. a DS-GVO.

Furthermore, you can prevent the collection of the data generated by the cookie and related to your use of the website (incl. your IP address) as well as the processing of this data by Google by downloading and installing a browser add-on (

As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on the following link: Deactivate Google Analytics. An opt-out cookie will be set, which prevents the future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

You can view the Google Analytics privacy policy at:

11. Plugins and other services

11.1 Google Tag Manager

On this website we use the Google Tag Manager service. The operating company of Google Tag Manager is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Through this tool, “website tags” (i.e. keywords which are integrated into HTML elements) can be implemented and managed via an interface. By using the Google Tag Manager, we can automatically track which button, link or personalised image you have actively clicked on and can then record which contents of our website are of particular interest to you.

The tool also triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If you have opted out at the domain or cookie level, this will remain in place for all tracking tags implemented with Google Tag Manager.

These processing operations are only carried out if express consent has been given in accordance with Art. 6 (1) lit. a DS-GVO.

Further information on Google Tag Manager and Google’s privacy policy can be found at:

11.2 Google WebFonts

Our website uses so-called Web Fonts for the uniform display of fonts. The Google WebFonts are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

These processing operations are only carried out if express consent is given in accordance with Art. 6 (1) a DS-GVO.

Further information on Google WebFonts and Google’s privacy policy can be found at: ;

11.3 Zoho SalesIQ

We use SalesIQ of the provider Zoho Corporation, 4141 Hacienda Drive Pleasanton, CA 94588, USA (“Zoho SalesIQ”).

Zoho SalesIQ uses so-called Java Scripts, which are executed on your computer and which enable an analysis of your use of the website. The information generated by the script about your use of the website (including your IP address) is transmitted to and stored by Zoho on a server – and possibly a backup server – within Europe. Zoho will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Zoho may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Zoho’s behalf.

The provider of Zoho SalesIQ necessarily obtains knowledge of the above-mentioned data, insofar as this is provided for in the context of our order processing contract (Art. 28 DS-GVO), with Zoho SalesIQ. This may include IP addresses, but also names, addresses, email addresses and telephone numbers.

Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a) DS-GVO. The legal basis for the use of Zoho SalesIQ in the context of contractual relationships is Art. 6 para. 1 lit. b) DS-GVO. In all other cases, the legal basis for processing your personal data is Art. 6 para. 1 lit. f) DS-GVO. Here, our interest is in the effective coordination of internal as well as external communication and the management of customer relationships.

To the extent that Zoho SalesIQ processes personal data in connection with its own legitimate business operations, Zoho SalesIQ is an independent data controller for such use and as such is responsible for compliance with applicable laws and obligations of a data controller.

Zoho SalesIQ’s privacy policy can be viewed at:

12. Your rights as a data subject

12.1 Right to Acknowledgement

You have the right to request confirmation from us as to whether personal data relating to you is being processed.

12.2 Right to information Art. 15 DS-GVO

You have the right to obtain from us, at any time and free of charge, information about the personal data stored about you as well as a copy of this data in accordance with the legal provisions.

12.3 Right to rectification Art. 16 DS-GVO

You have the right to demand that incorrect personal data concerning you be corrected. You also have the right to request that incomplete personal data be completed, taking into account the purposes of the processing.

12.4 Deletion Art. 17 DS-GVO

You have the right to demand that we delete the personal data concerning you without delay, provided that one of the reasons provided for by law applies and insofar as the processing or storage is not necessary.

12.5 Restriction of processing Art. 18 DS-GVO

You have the right to demand that we restrict processing if one of the legal requirements applies.

12.6 Data portability Art. 20 DS-GVO

You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO or on a contract pursuant to Art. 6(1)(b) DS-GVO and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have the personal data transferred directly from one controller to another controller, insofar as this is technically feasible and insofar as this does not adversely affect the rights and freedoms of other persons.

12.7 Objection Art. 21 DS-GVO

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DS-GVO.

This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves the purpose of asserting, exercising or defending legal claims.

In individual cases, we process personal data in order to carry out direct advertising. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is connected with such direct advertising. If you object to us processing your personal data for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, you have the right to object on grounds relating to your particular situation to the processing of personal data concerning you which is carried out by us for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation, unless such processing is necessary for the performance of a task carried out in the public interest.

You are free to exercise your right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

12.8 Withdrawal of consent under data protection law

You have the right to revoke consent to the processing of personal data at any time with effect for the future.

12.9 Complaint to a supervisory authority

You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.

13. up-to-dateness and amendment of the data protection declaration

This data protection declaration is currently valid and has the status: August 2022.

Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can access and print out the current data protection statement at any time on the website at