Privacy Policy

Status: September 2026

1. Data Protection 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 with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the "Information on the Controller" section of this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter into a contact form, provide when registering a user account, or when registering for an event.

Other data is collected automatically or after your consent by our IT systems when you visit the website. This is primarily 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?

Part of the data is collected to ensure the error-free provision of the website. Other data may be used to analyze your user behavior or for marketing purposes. Insofar as contracts can be concluded or initiated via the website (e.g., event registrations), the transmitted data will also be processed for this purpose.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient, and purpose of your stored personal data. You also have a right to request the rectification or erasure of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. Furthermore, you have the right to request the restriction of the processing of your personal data under certain circumstances. You also 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 on the subject of data protection.

2. Hosting and Website Provision

Lovable (Platform and Hosting)

Our website was created using the Lovable platform and is provided via their infrastructure. The provider is Lovable Labs Incorporated, 1111b South Governors Avenue, Dover, DE 19904, USA (EU branch: Lovable Labs AB, Stockholm, Sweden; hereinafter "Lovable").

When you access our website, Lovable processes technically necessary data, in particular server log files (IP address, date and time of access, page accessed, user agent/browser information). Processing is carried out on the basis of Art. 6(1)(f) GDPR; we have a legitimate interest in the secure, stable, and efficient provision of our website. Server log files are deleted after 30 days, unless they are exceptionally required for a longer period to investigate a specific security incident.

We have concluded a Data Processing Agreement (DPA) with Lovable in accordance with Art. 28 GDPR. As Lovable is a US company, a transfer to the USA cannot be excluded; this is based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). Further information: https://lovable.dev/privacy and https://lovable.dev/data-processing-agreement

The backend infrastructure (Lovable Cloud) is based on Supabase; details can be found in the section "Database and Backend Infrastructure (Supabase)".

IONOS (Domain and DNS)

Our domain is managed via IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany (domain registration and DNS). During name resolution, IONOS processes connection data (in particular IP addresses of requesting systems). Processing is carried out on the basis of Art. 6(1)(f) GDPR (legitimate interest in the reliable accessibility of our website). Details: https://www.ionos.de/datenschutzerklaerung

Cloudflare (Content Delivery and Attack Protection)

Our website is delivered via the content delivery and security network of Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA (EU representative: Cloudflare Germany GmbH, Rosental 7, 80331 Munich, Germany). Connection data is processed in this context, in particular your IP address, the requested address, the time of access as well as browser and device information. The purpose is the fast and reliable delivery of our content and the mitigation of attacks.

For this purpose Cloudflare sets a technically necessary cookie (“__cf_bm”) that distinguishes human access from automated requests. The legal basis is Art. 6 para. 1 lit. f GDPR; we have a legitimate interest in the secure and efficient operation of our website. Setting this cookie is permitted without consent pursuant to Section 25(2) no. 2 TDDDG.

Cloudflare acts as a sub-processor within our hosting arrangement and is covered by the data processing agreement concluded with our hosting provider. Any transfer to the USA is based on the EU standard contractual clauses (Art. 46 para. 2 lit. c GDPR). Further information: https://www.cloudflare.com/en-gb/privacypolicy/

3. General Information and Mandatory Information

Data Protection

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

When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. 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., when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

Information regarding the responsible party

The responsible party for data processing on this website is:

Digital Hub Region Bruchsal e.V.
Werner-von-Siemens-Strasse 2-6, Building 5137c, 76646 Bruchsal, Germany

Represented by the board: Niklas Rauber (Executive Board Member)

Phone: +49 7251 38225-0
E-mail: info@hubwerk01.de

The responsible party 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, e-mail addresses, or similar).

Storage Duration

Unless a more specific storage period has been specified 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 law retention periods); in the latter case, the deletion will take place after these reasons no longer apply.

General information on the legal basis for data processing on this website

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

Recipients of personal data

As part of our business activities, we work together with various external bodies. In some cases, it is also necessary to transfer personal data to these external bodies. We only pass on personal data to external bodies if this is necessary within the framework of contract fulfillment, if we are legally obliged to do so (e.g., passing on data to tax authorities), if we have a legitimate interest according to Art. 6 Para. 1 lit. f GDPR in the disclosure, or if another legal basis allows the data transfer. When using processors, we only pass on personal data of our customers on the basis of a valid contract for data processing. 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 express consent. You can revoke consent already given at any time. The legality of the data processing carried out until 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 Para. 1 lit. e or f GDPR, you have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data; 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 processing that outweigh your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims (objection according to Art. 21 Para. 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 the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection according to Art. 21 Para. 2 GDPR).

Right of appeal to 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, their place of work, or the place of the alleged violation. The right of appeal exists without prejudice to other administrative or judicial remedies.

The supervisory authority responsible for us is: Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg, Heilbronner Straße 35, 70191 Stuttgart, https://www.baden-wuerttemberg.datenschutz.de

No automated decision-making

Automated decision-making including profiling with legal effect or comparable significant impairment in the sense of Art. 22 GDPR does not take place.

Right to data portability

You have the right to have data that we process automatically on the basis of 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 responsible party, this will only be done as far as it is technically feasible.

Access, rectification and erasure

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of data processing and, if necessary, a right to rectification or erasure of this data. You can contact us at any time for this purpose and for further questions on the subject of 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 for this purpose. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we usually need time to check this. For the duration of the review, 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 erasure.
• 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 erasure.
• If you have lodged an objection according to Art. 21 Para. 1 GDPR, a balance must be struck between your interests and ours. 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 establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

SSL or TLS encryption

This site uses 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. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

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

Objection to promotional e-mails

The use of contact data published within the scope of the legal notice obligation for the purpose of sending unsolicited advertising and information materials is hereby rejected. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data Collection on this Website

Consent Management (Consent Banner)

When you first visit our website, a consent banner is displayed, through which you can grant or refuse your consent to the use of cookies and comparable technologies, or select individual categories (Art. 6 para. 1 lit. a GDPR, Section 25 para. 1 TDDDG). The banner is a proprietary technical solution of this website; no external consent service provider is used, and no data is transmitted to third parties for this purpose.

The services are divided into the following categories:

• Necessary (always active): Session and login functions, storage of your cookie decision
• Functional: Chatbot, YouTube embeds, Google Maps
• Statistics: Google Analytics 4
• Marketing: Google Tag Manager, Google Ads

Scripts and content requiring consent are only loaded after you have activated the respective category. Your decision is additionally signaled to Google services via the Google Consent Mode v2. Technically required storage and access processes take place without consent on the basis of Section 25 para. 2 TDDDG or Art. 6 para. 1 lit. f GDPR.

Your decision (consent status per category, timestamp, banner version) is stored exclusively locally in your browser (local storage entry "hw01_cookie_consent"); no server-side storage takes place. The storage period is 12 months; after that, you will be asked for your consent again. In the event of a revocation, the cookies set by the respective category will be deleted. If the categories or the banner version change, the banner will be displayed again. The Google Consent Mode v2 is implemented with the default setting "denied," so that Google tags do not transmit any personal data without your consent.

You can change or revoke your consent at any time with effect for the future via the "Cookie Settings" link in the footer of this website. Alternatively, you can delete the locally stored data via your browser settings; the banner will then be displayed again during your next visit.

Cookies

Our internet pages use so-called "cookies." Cookies are small data packets and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until your web browser performs an automatic deletion.

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.

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

Cookies that are required to carry out the electronic communication process, to provide certain functions you requested, or to optimize the website (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. 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 for the storage of cookies and comparable recognition technologies has been requested, processing takes place exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TDDDG); consent can be revoked at any time.

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. Deactivating cookies may restrict the functionality of this website.

Contact Form and Email Contact

If you send us inquiries via contact form or email, 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 the event of follow-up questions. To deliver your enquiry to us and to send you a confirmation copy, we use the email delivery service Resend (see the section "Transactional emails"); the data you provide, including the text of your message, is transmitted to Resend and processed there in the USA. Beyond that, we do not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR), if this has been requested.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent for storage, or the purpose for data storage no longer applies. Mandatory legal provisions – in particular retention periods – remain unaffected. The data transmitted via the contact form is stored in our database infrastructure at Supabase (see below).

AI Readiness Check

At hubwerk01.de/ki-check you can carry out a self-assessment of your organisation's AI readiness. Your answers are evaluated exclusively in your browser. As long as you do not submit the form at the end, we neither transmit nor store any answers.

If you request the detailed report, we process your name, your email address, optionally your organisation and phone number, your answers, the result calculated from them and whether you would like an initial consultation. We use this data to send you the report by email and, if requested, to contact you about a free initial consultation. To send the report to you and the notification to us, we use the email delivery service Resend (see the section "Transactional emails"); the data mentioned is transmitted to Resend and processed there in the USA. The notification is sent to our business email mailbox (see the section "Business Email Communication (Microsoft 365)"). The data is stored in our database infrastructure at Supabase (see below).

The legal basis is your consent (Art. 6 para. 1 lit. a GDPR). You can withdraw it at any time with effect for the future, for example by emailing info@hubwerk01.de. To prevent misuse, we limit the number of requests; for this purpose your IP address is stored briefly and usually deleted automatically after one hour (Art. 6 para. 1 lit. f GDPR, legitimate interest in the secure operation of the website).

Registration and User Account

You can register on our website to use additional functions. We use the data entered for this purpose (in particular email address, name, password in hashed form) 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 decline the registration.

Processing takes place for the purpose of executing the user relationship established by the registration and, if applicable, for the initiation of further contracts (Art. 6 para. 1 lit. b GDPR). The data collected during registration will be stored by us as long as you are registered on our website and will be deleted thereafter. Legal retention periods remain unaffected.

Registration for Events and Room Bookings

When registering for events and booking rooms via our website, we process the data requested in the respective form (e.g., name, email address, organization if applicable, booking period) for the organization and execution of the event or for processing the room booking, including participant and booking management as well as associated communication (e.g., booking confirmations via email). The legal basis is Art. 6 para. 1 lit. b GDPR.

Registration for training courses via online forms: Registration for some of our training courses and workshops takes place via forms provided by Asana, Inc. (USA). When you click the registration button on a course page, you are forwarded to such a form; the data you enter there is collected and processed directly by Asana. The purpose is to organise the registration and run the event. The legal basis is Art. 6 para. 1 lit. b GDPR. A transfer to the USA cannot be ruled out; Asana, Inc. is certified under the EU-U.S. Data Privacy Framework, and we have concluded a data processing agreement with Asana pursuant to Art. 28 GDPR. Further information on data protection at Asana: asana.com/terms

For internal processing, booking processes are created in the project management tool Asana (provider: Asana, Inc., USA). In the process, contact and booking data may be transmitted to Asana. We have concluded a data processing agreement with Asana in accordance with Art. 28 GDPR; Asana, Inc. is certified under the EU-U.S. Data Privacy Framework. Further information: https://asana.com/privacy

The data will be deleted after the event has concluded or the booking has been processed, provided that no legal retention obligations (e.g., Sections 147 AO, 257 HGB for paid events and bookings – up to 10 years) exist.

For internal scheduling we provide a password-protected calendar export through which bookings are transferred into the calendars of our staff (Microsoft 365). Access is only possible via a secret address that can be revoked at any time. The legal basis is Art. 6 para. 1 lit. b GDPR as well as Art. 6 para. 1 lit. f GDPR (legitimate interest in reliable internal scheduling).

Information about our staff and committee members

On the "Team" and "Committees" pages we publish the names, roles, photographs and business contact details (email address, telephone number, in some cases professional network profile) of the persons listed there. The purpose is to present our organisation and to make the responsible contact persons directly reachable. The legal basis is the consent of the person concerned (Art. 6 para. 1 lit. a GDPR) and, for business contact details, additionally our legitimate interest in transparent external communication (Art. 6 para. 1 lit. f GDPR). The information is removed as soon as the person requests it or no longer works for us.

Partner and Member Directory

In our public partner directory we publish the business contact details of the respective partner companies (including email address and telephone number) with their consent. This information is accessible without logging in. The legal basis is Art. 6 para. 1 lit. f GDPR (legitimate interest in presenting our network) or the consent of the respective company.

Transactional Emails (Resend)

For sending automated system emails – in particular booking and registration confirmations for room bookings – we use the Resend service from the provider Resend, Inc. (USA). In the process, the data required for dispatch (in particular email address, name, content of the confirmation message such as booking data) is transmitted to Resend and processed on servers in the USA.

The legal basis is Art. 6 para. 1 lit. b GDPR (performance of a contract or implementation of pre-contractual measures) as well as our legitimate interest in the reliable and secure dispatch of system emails (Art. 6 para. 1 lit. f GDPR).

We have concluded a data processing agreement (Data Processing Addendum) with Resend in accordance with Art. 28 GDPR, which incorporates the EU Standard Contractual Clauses (Art. 46 para. 2 lit. c GDPR). Resend, Inc. is also certified under the EU-U.S. Data Privacy Framework (DPF). Further information: https://resend.com/legal/privacy-policy and https://resend.com/legal/dpa

Business Email Communication (Microsoft 365)

Our business email accounts are operated via Microsoft 365 (provider: Microsoft Ireland Operations Ltd., One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). When you communicate with us via email, your email address and the communication content are processed on Microsoft servers.

The legal basis is Art. 6 para. 1 lit. b GDPR (contract-related communication) or our legitimate interest in a reliable and secure email infrastructure (Art. 6 para. 1 lit. f GDPR). We have concluded a data processing agreement with Microsoft in accordance with Art. 28 GDPR. Email correspondence is deleted after 6 years (commercial letters, Section 257 HGB) or 10 years for tax-relevant content (Section 147 AO). A transmission to the USA cannot be ruled out; Microsoft Corporation is certified under the EU-U.S. Data Privacy Framework. Further information: https://privacy.microsoft.com/de-de/privacystatement

Database and Backend Infrastructure (Supabase)

For storing user data (contact enquiries, user accounts, event registrations, bookings including uploaded files, and newsletter subscriptions with proof of consent) as well as for user authentication (Supabase Auth), we use the Supabase service from the provider Supabase, Inc. (USA) as part of the Lovable Cloud. Data storage takes place in a server region within the EU (Ireland).

We have concluded a data processing agreement with Supabase in accordance with Art. 28 GDPR. Since Supabase is a US company, access from a third country cannot be completely ruled out; for any third-country transmissions, the EU Standard Contractual Clauses (Art. 46 para. 2 lit. c GDPR) have been agreed upon. Further information: https://supabase.com/privacy

The legal basis for processing is the respective legal basis applicable to the underlying process (see the sections on contact form, registration, and event registration).

AI Chatbot

An AI-powered chat assistant is available on our website. The chatbot only becomes usable after you have activated the "Functional" category in the cookie settings; no data transmission takes place before your consent.

When you use the chatbot, your inputs including associated metadata (e.g., timestamp, technical connection data) are transmitted via the Lovable AI Gateway to the AI model Google Gemini (Google Ireland Limited or Google LLC) to generate a response. We recommend not entering any sensitive personal data into the chat. A transmission to the USA cannot be ruled out; it is based on the EU Standard Contractual Clauses and – for Google LLC – on the EU-U.S. Data Privacy Framework.

The legal basis is your consent (Art. 6 para. 1 lit. a GDPR, Section 25 para. 1 TDDDG). The chatbot's responses are generated using artificial intelligence; you will be additionally informed of this directly in the chat window. Chat histories are not stored: your messages are processed solely to generate the reply and are neither saved in our database nor retained permanently by the AI provider.

Use of Artificial Intelligence in the Creation and Operation of the Website

Our website was created and is managed using the AI-powered service Lovable (Lovable Labs Incorporated) (see section "Hosting"). The use of AI-powered technologies is based on Art. 6 para. 1 lit. f GDPR; we have a legitimate interest in using modern technologies to improve our outputs and services.

5. Newsletter

Newsletter Data

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter (double opt-in). No further data is collected, or only on a voluntary basis. To provide proof of the registration process, we store the time of registration, the time of confirmation, the version of the consent text and the place where you subscribed. We do not store your IP address for this purpose. We use the newsletter service provider described below to process the newsletter.

Delivery via HubSpot

We first store your subscription in our own database (see the section "Database and backend infrastructure"). The email you use to confirm your subscription (double opt-in) is sent via the service Resend (see the section "Transactional emails"). Only after your confirmation do we transfer your data to our CRM system HubSpot (provider: HubSpot, Inc., USA), where the newsletters are created and sent.

Performance measurement

HubSpot analyses whether a newsletter message was opened and which links in it were clicked. This helps us improve content and sending times. The basis is the consent you expressly give when subscribing (Art. 6 para. 1 lit. a GDPR). You can withdraw it at any time with effect for the future by unsubscribing via the link at the end of every message.

Legal basis

Processing is based on your consent (Art. 6 para. 1 lit. a GDPR). The lawfulness of processing carried out before withdrawal remains unaffected.

Retention period

After you unsubscribe, we mark your entry as unsubscribed and no longer use it for sending. Your email address remains stored for up to 3 years – firstly to reliably prevent future mailings, secondly to be able to prove the consent given (legitimate interest under Art. 6 para. 1 lit. f GDPR); after that, we delete the entry. As evidence we retain the time of your subscription, the time of your confirmation, the version of the consent text and the place where you subscribed. You may object to this storage if your interests outweigh our legitimate interest; we will then delete your entry entirely.

Data processing agreement

We have concluded a data processing agreement with HubSpot pursuant to Art. 28 GDPR; HubSpot, Inc. is certified under the EU-U.S. Data Privacy Framework. Further information: legal.hubspot.com/privacy-policy

6. Social Media

We maintain profiles on social networks (including Facebook, Instagram and LinkedIn). This website contains only simple links to these profiles. No plugins, SDKs or other active elements of the providers are loaded; therefore no data is transmitted to the operators of the social networks when you visit our website.

Only when you click one of these links are you forwarded to the pages of the respective provider; from that point on, their privacy policies apply. The respective provider is responsible for processing your data on the platforms themselves. Insofar as we are jointly responsible with the provider for the processing of visitor data on our profile pages (Art. 26 GDPR), this is based on our legitimate interest in public relations and communication (Art. 6(1)(f) GDPR).

7. Analysis Tools and Advertising

Google Tag Manager

We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies into our website. Google Tag Manager itself does not create user profiles, does not store cookies, and does not perform any independent analyses. It serves solely to manage and deploy the tools integrated through it. However, Google Tag Manager records your IP address, which may also be transmitted to Google's parent company in the United States.

Google Tag Manager is assigned to the "Marketing" category in our consent banner and only becomes usable after you have activated this category. The processing is therefore performed exclusively on the basis of your consent (Art. 6 (1) (a) GDPR, Section 25 (1) TDDDG). Consent can be revoked at any time with effect for the future.

The company holds a DPF certification: https://www.dataprivacyframework.gov/participant/5780

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, duration of visit, operating systems used, and the origin of the user. This data is assigned to the respective end device of the user. Assignment to a user ID does not occur. Furthermore, Google Analytics uses various modeling approaches to supplement the collected data sets and employs machine learning technologies for data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g., cookies or device fingerprinting). In Google Analytics 4, IP addresses are not stored by default, but are only used for rough location derivation and are subsequently discarded. Information collected by Google about the use of this website may be transmitted to Google servers – including those in the USA – and stored there.

The use of this service is based exclusively on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. Consent can be revoked at any time.

Data transmission to the USA is based on the Standard Contractual Clauses of the EU Commission. Details: https://business.safety.google/adscontrollerterms/sccs/

The company holds a DPF certification: https://www.dataprivacyframework.gov/participant/5780

Browser Plugin

In addition to revocation via the cookie settings, you can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de

More information on how Google Analytics handles user data can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=de

Storage Period

User and event data stored in Google Analytics will be automatically deleted after 14 months.

Data Processing Agreement

We have concluded a data processing agreement with Google in accordance with Art. 28 GDPR.

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms into Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on user data available at Google (e.g., location data and interests) (target group targeting). As the website operator, we can quantitatively evaluate this data by, for example, analyzing which search terms led to the display of our advertisements and how many advertisements led to corresponding clicks.

The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. Consent can be revoked at any time.

Data transmission to the USA is based on the Standard Contractual Clauses of the EU Commission. Details: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms/

The company holds a DPF certification: https://www.dataprivacyframework.gov/participant/5780

Meta Pixel (Facebook)

Our website is technically prepared to use the visitor action pixel of Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, Ireland. This would allow us to follow the behaviour of visitors who reached our website through an advertisement on Facebook or Instagram. The pixel belongs to the "Marketing" category and would be loaded only after your express consent (Art. 6 para. 1 lit. a GDPR, Sec. 25 para. 1 TDDDG).

At present no Meta Pixel is set up; no data is transmitted to Meta. Should we use the pixel in future, we will list it in the consent banner beforehand. Meta Platforms Ireland Ltd. is certified under the EU-U.S. Data Privacy Framework; a transfer to the USA cannot be ruled out and is based on the EU standard contractual clauses. Further information: facebook.com/privacy/policy

Google Conversion Tracking

This website uses Google Conversion Tracking. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

With the help of Google Conversion Tracking, Google and we can recognize whether the user has performed certain actions. For example, we can evaluate which buttons on our website were clicked how often and which offers were viewed particularly frequently. This information is used to create conversion statistics. We learn the total number of users who clicked on our ads and what actions they took. We do not receive any information that allows us to personally identify the user.

The use of this service is based on your consent pursuant to Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG. Consent can be revoked at any time.

More information: https://policies.google.com/privacy?hl=de – DPF certification: https://www.dataprivacyframework.gov/participant/5780

8. Plugins and Tools

YouTube with Enhanced Data Protection

This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit a page on which YouTube is embedded, a connection to YouTube's servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

YouTube videos are only loaded on our website once you actively confirm this (two-click solution) or have activated the "Functional" category in the cookie settings. No connection to YouTube is established and no data is transferred to Google before this confirmation.

Furthermore, we use YouTube in enhanced data protection mode. According to YouTube, videos played in enhanced data protection mode are not used to personalize the surfing experience on YouTube. In enhanced data protection mode, no cookies are set; instead, so-called local storage elements are stored in the browser, which, similar to cookies, contain personal data and can be used for recognition. Details: https://support.google.com/youtube/answer/171780

YouTube embeds are assigned to the "Functional" category in our consent banner and are only loaded after your confirmation or consent. Processing therefore takes place exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR, Section 25 para. 1 TDDDG). Consent can be revoked at any time with effect for the future.

Further information: https://policies.google.com/privacy?hl=de – DPF certification: https://www.dataprivacyframework.gov/participant/5780

Google Fonts (local hosting)

This site uses so-called Google Fonts, provided by Google, for the uniform display of fonts. The Google Fonts are installed locally. A connection to Google's servers does not take place.

Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=de

Google Maps

This site uses the mapping service Google Maps. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of this service, we can embed map material on our website.

The map is only loaded once you actively confirm this (two-click solution) or have activated the "Functional" category in the cookie settings. No connection to Google is established before this confirmation.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google may use Google Fonts for the purpose of uniform font display.

Google Maps is assigned to the "Functional" category in our consent banner. The map is only loaded after your consent; processing therefore takes place exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR, Section 25 para. 1 TDDDG). Consent can be revoked at any time with effect for the future.

Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission. Details: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/

More information: https://policies.google.com/privacy?hl=de – DPF certification: https://www.dataprivacyframework.gov/participant/5780

9. eCommerce and Payment Providers

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content design, and modification of 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 for billing purposes. The legal basis for this is Art. 6 para. 1 lit. b GDPR.

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

Data Transfer upon Conclusion of Contract for Services and Digital Content

We only transfer personal data to third parties if this is necessary within the scope of contract processing. Payments are not processed via this website; billing takes place exclusively by invoice outside the website. No payment service provider is integrated.

Further transmission of data does not take place or only takes place if you have expressly consented to the transmission. Your data will not be passed on to third parties without express consent, for example for advertising purposes.

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

10. Transfer to third countries

Insofar as we transfer data to countries outside the EU or the EEA (in particular the USA), this only takes place if an adequacy decision of the EU Commission is in place (in particular the EU-U.S. Data Privacy Framework for certified US companies), appropriate safeguards such as EU standard contractual clauses (Art. 46 GDPR) have been agreed, or you have given your express consent (Art. 49 para. 1 lit. a GDPR).

11. Use of AI systems (transparency notice under Art. 50 EU AI Act)

We use AI systems on this website and label them transparently:

• AI chat assistant: The chat on this website is powered by an AI language model (provided via our backend provider or our hosting provider's AI gateway). Its purpose is the automated answering of general questions about rooms, training and membership. We process the messages you enter as well as technical metadata. The legal basis is your consent (Art. 6 para. 1 lit. a GDPR, Sec. 25 para. 1 TDDDG), which you give via the "Functional" category in the consent banner and may withdraw at any time. Chat histories are not permanently stored in a personally identifiable form and are not used to train AI models. Please do not enter sensitive or special categories of personal data (Art. 9 GDPR) into the chat.
• AI-assisted translation: The English content of this website is partly machine-translated with AI support. The German version is always authoritative and legally binding.

There is no automated decision-making, including profiling, within the meaning of Art. 22 GDPR. Answers from the AI assistant are non-binding and may contain errors; a human contact is always available at info@hubwerk01.de. Further information can be found on our AI Transparency page.

Voice input in the AI chat: The AI chat optionally offers a dictation feature. An audio recording is only created via your microphone if you actively start the recording, and it is transmitted solely for conversion into text. For this we use the model GPT-4o-mini-transcribe from OpenAI, L.L.C. (USA), which we address via our hosting provider's AI gateway; your recording is thereby transferred to the USA. The transfer is based on the EU standard contractual clauses. The recording is not stored permanently; the recognised text appears in the input field and is only processed once you send it. The legal basis is your consent (category "Functional", Art. 6 para. 1 lit. a GDPR), which you may withdraw at any time.

12. Overview of processors (Art. 28 GDPR)

We have concluded data processing agreements pursuant to Art. 28 GDPR with the service providers listed below, insofar as they act as processors on our behalf. For the embedded Google services, Google acts as an independent controller; the basis there is your consent. Where processing takes place outside the EU/EEA, it is safeguarded by an adequacy decision (EU-U.S. Data Privacy Framework) and/or EU standard contractual clauses (Art. 46 GDPR).

Provider	Location	Purpose	Basis
Lovable Labs Incorporated (platform, hosting) and Supabase, Inc. (database, file storage, serverless functions)	USA (data centre in the EU/Ireland)	Website operation, storage of booking, contact and newsletter data, file uploads	Processing agreement concluded, EU standard contractual clauses
Resend	USA	Sending system emails (booking, registration and newsletter confirmations)	Processing agreement concluded, EU standard contractual clauses
HubSpot	USA / Ireland	CRM: managing newsletter subscriptions and booking records as well as creation, delivery and performance measurement of the newsletters	Processing agreement concluded, EU standard contractual clauses
Asana	USA	Internal task management for booking enquiries	Processing agreement concluded, EU standard contractual clauses
AI providers via our hosting provider's AI gateway: Google (chat responses), OpenAI, L.L.C. (converting voice input into text)	EU/USA	Generating chat responses, speech recognition in the chat	Processing agreement concluded, EU standard contractual clauses
Microsoft Ireland Operations Ltd.	Ireland (parent company USA)	Staff email mailboxes and calendars	Processing agreement concluded, EU-U.S. Data Privacy Framework
Google Ireland Ltd. (Google Maps, YouTube, Tag Manager, Google Analytics 4, Google Ads including conversion tracking)	Ireland/USA	Maps, video embedding, tag management, audience measurement, conversion measurement – loaded only after your consent	Consent (Art. 6 para. 1 lit. a GDPR)

Fonts (Titillium Web) are served locally from our server; no connection to Google Fonts is established.

13. Data protection officer

We are not legally required to appoint a data protection officer (Art. 37 GDPR, Sec. 38 BDSG) and have therefore not appointed one. For all data protection questions and to exercise your rights, please contact the controller named above: Digital Hub Region Bruchsal e.V., Werner-von-Siemens-Strasse 2-6, Building 5137c, 76646 Bruchsal, Germany, email: info@hubwerk01.de.

14. Your rights as a data subject

You have the right to information (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR), data portability (Art. 20 GDPR) and to object to processing based on legitimate interests (Art. 21 GDPR) at any time. You may withdraw consent at any time with effect for the future (Art. 7 para. 3 GDPR). Please contact info@hubwerk01.de.

You also have the right to lodge a complaint with a supervisory authority. The authority responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg, Heilbronner Straße 35, 70191 Stuttgart, Germany, phone +49 711 615541-0, email: poststelle@lfdi.bwl.de

15. Storage and deletion periods

• Room bookings: booking and invoice data are retained for 6 or 10 years in line with commercial and tax retention obligations (Sec. 257 HGB, Sec. 147 AO).
• Files uploaded with bookings: deleted no later than 12 months after the event, unless retention obligations apply.
• Contact enquiries: deleted once the enquiry has been fully processed, at the latest after 24 months. If an enquiry develops into business email correspondence subject to commercial or tax retention obligations, the periods of 6 or 10 years stated in the section on business email communication apply instead.
• AI Readiness Check: deleted once the request has been fully processed (report sent and, if requested, initial consultation held), at the latest after 24 months; without delay after consent has been withdrawn. If a request develops into business email correspondence subject to commercial or tax retention obligations, the periods of 6 or 10 years stated in the section on business email communication apply instead.
• Newsletter: stored until unsubscribing. After that, the email address remains stored as a suppression-list entry and the proof of consent (time of subscription and confirmation, version of the consent text, place of subscription) for up to 3 years after unsubscribing; they are then deleted.
• Chat histories: kept only for the duration of the session in your browser and not archived in personally identifiable form.
• Customer accounts: deleted on request or at the latest 24 months after the last activity.
• Administration and security logs (audit log): 12 months.

16. Consent management (cookie banner)

On your first visit, a consent banner asks for your decision. Without your consent, no non-essential cookies are set and no external services (Google Maps, YouTube, Google Tag Manager, Google Analytics 4, Google Ads) are loaded. Your decision is stored locally in your browser (retention 12 months) and can be changed or withdrawn at any time via the "Cookie settings" link in the website footer. The legal bases are Sec. 25 para. 1 TDDDG and Art. 6 para. 1 lit. a GDPR; technically necessary storage is based on Sec. 25 para. 2 TDDDG.

17. Amendments to this Privacy Policy

We will adapt this privacy policy as soon as changes to the website, the services used, or the legal situation make this necessary. The version currently published on this website shall apply.