General Privacy Notice

CONTRIMA is committed to protecting your privacy. The following information provides details regarding CONTRIMA’s processing of personal data. This privacy policy expressly refers to the website-specific data processing procedures when you visit our website at www.contrima.com. Even beyond the website-specific data processing procedures, CONTRIMA attaches great importance to the protection of personal data. Therefore, Therefore, please also take into account—to the extent applicable to you—our additional privacy notice for photographers, the current version of which you can access at any time via the following link:

Privacy Notice for Photographers

Our privacy notices are updated regularly and adapted to new legal requirements or case law. We therefore recommend that you revisit and read through these privacy notices on a regular basis.

I. Data Controller

The data controller is Contrima GmbH, represented by its managing director, Mr. Mark Reinhardt, Enzianweg 29, 71384 Weinstadt (hereinafter “CONTRIMA”).

Contact address: info@contrima.com

II. Processing of Personal Data, Legal Bases

This Privacy Policy informs you, in accordance with Art. 12 et seq. of the GDPR, about the handling of your personal data when you use our website. It explains, in particular, what data we collect and how we use it. It also informs you about how and for what purpose this is done.

We process your personal data in accordance with Article 6(1) of the GDPR, i.e., for the processing of your personal data, we either have your consent or there is another legal basis for doing so. We also work with service providers who process your personal data on our behalf (e.g., hosting the CONTRIMA website). Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”).

Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”) ; a natural person is considered identifiable if they can be identified, directly or indirectly—in particular by association with an identifier such as a name, an identifier number, location data, an online identifier, or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person (see Art. 4(1) GDPR). Personal data therefore also includes data that can be linked to a person, such as an IP address. Other examples include: title, first name, last name, job title, email address, company, street, ZIP code, and city.

Processing means any operation or set of operations performed on personal data, whether or not by automated means, data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or any other form of disclosure, the comparison or linking, the restriction, erasure, or destruction (see Art. 4(2) of the GDPR).

III. Purposes and Legal Bases for Data Processing

1. Automatic Data Processing When Accessing and Visiting the Website of CONTRIMA

When you visit our website, we collect and process the information that you automatically transmit to us through technical means and/or personal data that you voluntarily provide to us.

Each time you access our website, we process the following information automatically:

• IP address of the requesting device (computer, tablet, or smartphone)
• Date and time of access
• Content of the request (specific page or file)
• Access status/HTTP status code
• Amount of data transferred in each instance
• Browser used, including version and language

This technically necessary information is collected and processed to enable the use of the site, to ensure system security, and to detect and investigate any malfunctions or attacks. This information is stored in log files to ensure the functionality of the service, guarantee the security of our IT systems, and optimize our service.

The data mentioned above is also temporarily stored in our servers’ log files. This data is not stored together with any other personal data belonging to you.

The strictly necessary information is collected and processed in accordance with Section 25(2)(2) of the Telecommunications and Digital Services Data Protection Act (TDDDG).

The subsequent processing in log files is based on Article 6(1)(f) of the GDPR. Our legitimate interest lies in providing a functional and technically secure website, as well as in preventing and tracking any unlawful use. uses. In the case of data processing based on Article 6(1)(f) of the GDPR, you have the right to object; see Section IV below.

If you visit our website to learn about our range of products and services or to use them, the basis for the temporary storage and processing of access data is Article 6(1), sentence 1, subparagraph (b) of the GDPR, which permits the processing of data for the performance of a contract or for the implementation of precontractual measures; 2. Processing of contact requests

2. Processing of Contact Inquiries

If you send us inquiries via email to our contact address info@contrima.com, your messages, including the contact information you provide there (such as a personalized email address, name, contractual relationship with us, phone number, etc.) will be stored by us for the purpose of processing and responding to your inquiry, as well as in case of follow-up questions, and will be processed accordingly. Your personal data will be stored in our email or file storage system and, if necessary, assigned to an existing record. We do not disclose this data to third parties unless it is necessary processing and responding to your contact request, or you have given us your consent to do so.

If you contact us in the context of an existing contractual relationship or if you contact us in advance to obtain information about our range of services or our other offerings, , the data and information you provide will be processed for the purpose of processing and responding to your contact request in accordance with Art. 6(1), sentence 1, lit. b of the GDPR. Furthermore, to safeguard our legitimate interests pursuant to Art. 6(1), sentence 1, subparagraph (f) of the GDPR, for the proper handling of customer and contact inquiries.

The data you enter will remain with us until the purpose for the storage/processing of the data no longer applies (e.g., after your inquiry has been fully processed). If you wish, we will delete your personal data, provided we have no legal obligation or interest in retaining it further. A legitimate interest on our part in retaining the data exists with regard to the possible assertion of legal claims against us. In such cases, the data will be retained for at least three more years following the end of the year in which your request was finalized. Any other mandatory legal provisions—in particular retention periods—remain unaffected.

3. Use of Cookies, Audience Measurement, and Advertising

Our website uses cookies. Cookies are small text files that are stored on your device (e.g., computer, tablet, or smartphone) and enable us to recognize your browser when you visit the site again. We distinguish between technically necessary cookies (hereinafter “a.”) and cookies or services that we use only with your consent (hereinafter “b.” through “d.”).

a. Technically Necessary Cookies

Technically necessary cookies are required for the website to function properly. These include:

• session cookies for login and session management; they are automatically deleted at the end of your visit or browser session,
• cookies to store your language and country settings,
• the “ctm_consent” cookie, in which we store your selection from the cookie banner; (storage period: 182 days; see b.). It does not contain any identifier that could be used to recognize you; .

These cookies constitute “strictly necessary” information within the meaning of Section 25 (2) No. 2 of the Telecommunications and Digital Services Data Protection Act (TDDDG). The associated data processing is carried out on the basis of Art. 6(1), sentence 1, subparagraph f of the GDPR to safeguard our legitimate interests in a technically functional, user-friendly, and secure website, or on the basis of Article 6(1), first sentence, letter b of the GDPR, insofar as the cookies are necessary for the provision of contractually required functions (e.g., login). You can configure your browser so that you are notified when cookies are set and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for specific cases or in general, and disable the automatic acceptance of cookies.

You can configure your browser so that you are notified when cookies are set, and only allow cookies on a case-by-case basis, exclude the acceptance of cookies for specific cases or in general, and enable the automatic deletion of cookies when you close your browser, . You can usually find instructions on how to disable cookies via the “Help” function of your web browser. Disabling cookies may result in restricted functionality and/or limited availability of this website. b.

b. Consent via the Cookie Banner, Withdrawal, and Proof

We only use cookies and services for audience measurement (“Statistics”), for measuring the effectiveness of our ads (“Advertising Performance Measurement”), and for displaying personalized ads (“Personalized Advertising”) if you have given your prior consent. The first time you visit our public information pages (e.g., home page, features, pricing, FAQ, contact) as well as the registration page, we’ll display a banner with the buttons: “Accept All,” “Only Necessary,” and “Settings.” “Only Necessary” rejects all purposes that require consent. Under “Settings,” you can decide individually for each purpose. No category is preselected. The purposes available for you to choose from in the banner depends on which of the services described under c. and d. we are currently using. As long as you have not given your consent, no data will be transmitted to Google and none of the cookies mentioned under c. and d. will be set. We host the banner ourselves on our servers.

We store your selection—including a refusal—for 182 days; during this time, we will not display the banner to you again. If you close the banner without making a selection, this is not considered consent, and we will ask you again the next time you visit. If we change the purposes, the services, or the text of the banner, we will also ask you again.

On the pages featuring photographed individuals, in the galleries, in the photographers’ account area, and on our legal notices pages, we do not use cookies for audience measurement or for advertising purposes.

The legal basis for storing and accessing information on your device is your consent pursuant to Section 25(1) of the TDDDG—for visitors outside Germany, the corresponding regulation in their country. The legal basis for the subsequent processing of your personal data is your consent pursuant to Art. 6(1)(a) of the GDPR.

Withdrawal: You can withdraw your consent at any time with effect for the future or change your selection via the “Cookie Settings” menu item in the footer of each page. Upon revocation, we will delete the Google cookies on our domain; You can delete cookies that Google has set on its own domain (see d.) in your browser. Data that was already transmitted to Google prior to revocation is not affected by the revocation.

Evidence: We store your selection in the “ctm_consent” cookie (182 days). In addition, we log the following information anonymously—without an IP address, browser ID, identifier, or reference to an account—the time of the decision, the version of the banner, the page language, the page accessed, and the selection made for each purpose. The log serves as proof that and how we obtain consent (Art. 7(1) GDPR).

c. Google Analytics – Audience Measurement (“Statistics”)

With your consent for the “Statistics” purpose, we use Google Analytics (Version 4), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Ireland Limited engages Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, for the processing.

The purpose is to measure the reach and analyze the use of our public information pages (such as page views, sessions, referral source, device used, and browser). In addition, we track two events: the registration of an account and the completion of a subscription. When a subscription is completed, the plan price, currency, and subscription number are transmitted—a unique identifier that only we can associate with your account and that allows Google to detect duplicate counts. Names, email addresses, or other account data are not transmitted. The “Subscription completed” event is triggered once after you return from the payment process, and only if you have previously consented. The analytics data helps us improve our website and our offerings.

Google Analytics sets cookies that assign a random identifier to your browser: “_ga” (to distinguish users) and “_ga_” followed by our website’s identifier (session status), each with a retention period of up to two years (shorter depending on the browser). Google uses your IP address only to determine the approximate region from which the request originated; for users from the the EU, Switzerland, and the United Kingdom, it is not, according to Google, stored. Event data is retained by Google for 14 months; after that, only aggregated reports without reference to individual users remain.

Google processes this data on our behalf based on the Google Data Processing Terms in accordance with Art. 28 of the GDPR. To the extent that data is transferred to the U.S. , the transfer is based on the EU-U.S. Data Privacy Framework , including its UK extension, as well as the Swiss-U.S. Data Privacy Framework, under which Google LLC is certified. In this regard, the European Commission certifies, through an adequacy decision, that data protection is comparable to the EEA standard.

The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG); see b. for information on revocation. Additionally, you can prevent data collection by Google Analytics using the Google browser add-on: https://tools.google.com/dlpage/gaoptout. Further information on data protection with Google Analytics: https://policies.google.com/privacy and https://support.google.com/analytics/answer/6004245.

d. Google Ads – Performance Measurement and Personalized Advertising

Google Ads is an online advertising service provided by Google Ireland Limited (see c. for address). To the extent that we use Google Ads, we do so exclusively on the basis of your consent, for two purposes, each of which you can consent to individually:

• Advertising performance measurement: If you reached our website via a Google ad, we can track whether this subsequently led to a registration or to a subscription. When a subscription is purchased, the plan price and currency are transmitted—not names, email addresses, or other account data. This allows us to measure the success of our ads. To do this, Google sets cookies with the prefix “_gcl_” (e.g., “_gcl_au,” “_gcl_aw,” “_gcl_gs”) with a retention period of 90 days, which link the click on a ad to a subsequent registration or subscription.
• Personalized advertising: Google records that your browser has visited our website and can link this information with data from other websites that use Google services to show you CONTRIMA ads on websites and in services provided by Google and its advertising partners (remarketing). To do this, Google sets the “IDE” and “id” cookies on its own domain, doubleclick.net, with a storage period of up to 13 months—depending on whether your browser accepts third-party cookies. sets the “IDE” and “id” cookies on its own domain, doubleclick.net, with a storage period of up to 13 months—depending on whether your browser allows third-party cookies.

We ourselves receive only aggregated statistics from Google, not information about individual persons. We are responsible for the collection of this data on our website and its transmission to Google; Google is solely responsible for further processing of the data (Google Ads Controller-Controller Data Protection Terms). Information regarding the processing by Google can be found in Google’s Privacy Policy: https://policies.google.com/privacy. To the extent that data is transferred to the U.S., the transfer is based on the EU-U.S. Data Privacy Framework (see c.).

The legal basis is your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG); for revocation, see b. You can also disable personalized advertising by Google in your Google Account: https://myadcenter.google.com.

4. Links to Social Media Platforms/Websites

Our website contains links to websites, including social media platforms, that are operated by other companies. If you follow these links, you will be taken directly to the websites of these providers, who are responsible for the data processing that takes place there. We ourselves have no influence over the data processing that takes place there; we have no influence over the data processing that takes place there.

Please note that these websites very often use various cookies, and that data processing is frequently carried out by companies based in a third country, and data may be transferred to servers in a third country and thus processed outside the European Union.

5. Additional Purposes of Processing

a. Compliance with Legal Requirements

We also process your personal data to fulfill other legal obligations that may apply to us in connection with our business activities. These include, in particular, retention periods under commercial, trade, or tax law. In doing so, we process your personal data in accordance with Art. 6(1)(c) of the GDPR (legal basis) to fulfill a legal obligation to which we are subject.

b. Law Enforcement

We also process your personal data to assert our rights and enforce our legal claims. We also process your personal data to defend ourselves against legal claims. Finally, we process your personal data to the extent necessary to prevent or prosecute criminal offenses. In doing so, we process your personal data to safeguard our legitimate interests pursuant to Article 6(1)(f) of the GDPR, insofar as we assert legal claims or defend ourselves in legal disputes, or we prevent or investigate criminal offenses (legitimate interest).

6. Recipients of Personal Data

Within CONTRIMA, those departments that need your data to fulfill our contractual and legal obligations have access to it. Service providers and vicarious agents (e.g., technical service providers) that we engage may also receive data for these purposes. We limit the disclosure of your personal data to what is necessary, in accordance with data protection regulations. In some cases, recipients receive your personal data as subprocessors and are then strictly bound by our instructions when handling your personal data.

• Our website is hosted on servers operated by Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855 Luxembourg (“AWS”). We also use the email service provided by AWS (Amazon Simple Email Service). Processing is carried out on the basis of a data processing agreement in accordance with Art. 28 of the GDPR. To the extent that a transfer to the U.S. takes place in individual cases, the data transfer is based on the EU-U.S. Data Privacy Framework. In this regard, the European Commission certifies, through an adequacy decision, a level of data protection comparable to the EEA standard. You can view the privacy policy of Amazon Web Services, Inc. at: https://aws.amazon.com/de/privacy/.
• To process payments (such as for a subscription), we use the payment service provider Stripe (Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland). When you sign up for a subscription, you will be redirected to Stripe’s payment process: (www.stripe.com). Stripe may transfer data to the U.S. and is certified under the EU-U.S. Data Privacy Framework. Further information: https://stripe.com/de/privacy.
• Only with your consent (see Section III.3): For audience measurement and for advertising purposes, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, receives the data described there; it engages Google LLC, USA. For Google Analytics, Google is our data processor pursuant to Art. 28 of the GDPR; for further processing within the scope of Google Ads, Google is the independent data controller. The transfer to the U.S. is based on the EU-U.S. Data Privacy Framework, including its UK extension, as well as the Swiss-U.S. Data Privacy Framework, under which Google LLC is certified. Google’s Privacy Policy: https://policies.google.com/privacy.

IV. Your Rights as a Data Subject

1. Right to Withdraw Consent: You may withdraw your consent to the processing of personal data, granted pursuant to Art. 6(1)(a) of the GDPR, at any time by notifying us. Please note that the withdrawal takes effect only for the future. Processing that took place prior to the withdrawal is not affected. To declare your withdrawal, an informal notification—e.g., via email to us at: info@contrima.com—is sufficient. You may also revoke or change your consent to cookies and services for audience measurement and advertising (Section III.3) at any time directly via the menu item “Cookie Settings” at the bottom of each page.

2. Right to Object: You are entitled, under the conditions set forth in Article 21 of the GDPR—that is, in the case of processing based on legitimate interests pursuant to Article 6(1)(f) of the GDPR—to object to the processing of your personal data, so that we must cease processing your personal data. The right to object applies only within the limits set forth in Article 21 of the GDPR. Furthermore, our interests may override the processing, meaning that we are entitled, despite your objection, to process your personal data. We will take into account any objection to direct marketing measures immediately and without further weighing of the existing interests.

Information about your right to object under Article 21 of the GDPR: You have the right to object at any time to the processing of your data that is based on Article 6(1), sentence 1, (f) of the GDPR (data processing based on a balancing of interests) or Article 6(1) sentence 1 (e) of the GDPR (data processing in the public interest), to object if there are grounds for doing so arising from your particular situation. If you object, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims. The objection may be submitted in any form and should, if possible, be addressed to: info@contrima.com.

3. You have the right to request confirmation from us as to whether we process personal data concerning you. If this is the case, you have the right to access this personal data to the extent provided by law (Art. 15 GDPR in conjunction with § 34 BDSG).

4. You also have the right to request the rectification of any incorrect personal data concerning you, and, where applicable—taking into account the purposes of the processing—the completion of incomplete personal data, including by means of a supplementary statement, (Article 16 of the GDPR).

5. In the cases specified in Article 17(1)(a) through (f) of the GDPR, you also have a right to have your personal data erased, provided that no exception under Article 17(3) of the GDPR applies, as well as in the cases specified in Article 18(1) of the GDPR, a right to restriction of processing. 18(1) of the GDPR, you have the right to restriction of processing.

6. In the cases set forth in Article 20(1) of the GDPR, you also have a right to data portability.

7. You have the right to lodge a complaint with a supervisory authority, if you believe that the processing of your personal data violates the GDPR. The competent lead supervisory authority for us is: The State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg (LfDI BW), P.O. Box 10 29 32, 70025 Stuttgart, Email: poststelle@lfdi.bwl.de, Website: baden-wuerttemberg.datenschutz.de.

V. Data Security

We take all necessary technical and organizational security measures to protect your personal data from loss, unauthorized access, and misuse.

In particular, for security reasons and to protect the transmission of confidential content—such as the contact requests you send to us as the website operator—this website uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://,” as well as by the lock icon in your browser’s address bar. If SSL or TLS encryption is enabled, the data you transmit to us cannot be read by third parties. Nevertheless, we would like to point out that data transmission over the Internet (e.g., when communicating via email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible in this regard.

Our employees and the service providers we engage are bound by us to maintain confidentiality and to comply with data protection regulations.