A. General Information

As networker variant GmbH (hereinafter “networker” or “we”), we process personal data in accordance with applicable data protection laws, in particular the General Data Protection Regulation (GDPR). The following information explains how we process data within our area of responsibility.

B. General Principles

We process personal data in the course of our business activities. We disclose data to service providers and, where applicable, transfer data to countries outside the European Union (EU) or European Economic Area (EEA) only in compliance with applicable data protection requirements. Further details are provided below.

C. Controller

1 Contact Details

The controller responsible for processing your personal data within the meaning of the GDPR and the German Federal Data Protection Act (BDSG) is:

networker variant GmbH | Feldgasse 7A | 25996 Wenningstedt-Braderup | Germany

Telephone: +49 4651 9323 003

Email: info@networkervc.com

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.

2 Processing of Personal Data

The categories of data concerned, purposes, legal bases and recipients are described below.

2.1 Contacting Us

When you contact us, we process the following data to handle and respond to your enquiry: your name, contact details (if provided) and your message.

The legal basis is the performance of a contract or steps taken prior to entering into a contract under Article 6(1)(b) GDPR and/or our legitimate interest in responding to your enquiry under Article 6(1)(f) GDPR.

2.2 Server Logs When Visiting Our Website

We log visits to websites operated by us. The data processed may include:

• Name of the website or page accessed
• Date and time of access
• Amount of data transferred
• Browser type and version
• Operating system used
• Referrer URL (previously visited website)
• Your IP address
• Requesting internet service provider.

The legal basis is our legitimate interest in the continued availability and security of our website under Article 6(1)(f) GDPR.

We retain server log data only for as long as necessary for operation, security and investigating specific malfunctions or attacks. Actual retention periods depend on the hosting provider’s configuration and deletion rules and any statutory obligations.

2.3 Hosting by Elementor Hosting and Domain Management by IONOS

Our WordPress website is hosted by Elementor Hosting. In connection with the provision, technical administration, performance monitoring and security of the website, connection data, server data and technical usage data may be processed. The domain networkervc.com is managed through IONOS; the website itself is not hosted by IONOS.

Elementor Hosting uses infrastructure provided by Google Cloud Platform and Cloudflare, among others. These providers may act as sub-processors in connection with the operation of our website.

Technical Performance Monitoring (Real User Monitoring)

Elementor Hosting uses Real User Monitoring (RUM) to monitor the technical performance, availability and stability of our website. Data processed for this purpose may include loading times and performance metrics (such as Core Web Vitals), browser and device information, technical request identifiers, visited page URLs and HTTP status codes.

According to Elementor, this monitoring is not used for advertising profiles or cross-site tracking. The provider states that its standard RUM implementation does not use tracking cookies for visitor profiling.

The processing is based on Article 6(1)(f) GDPR, reflecting our legitimate interest in ensuring the secure, stable and efficient operation of our website, provided that the applicable legal requirements are met.

International Data Processing

As part of the hosting infrastructure and technical performance monitoring, personal data may be processed outside the European Union or European Economic Area, particularly in the United States or Israel. According to Elementor, appropriate data transfer mechanisms, including the European Commission’s Standard Contractual Clauses, are used for such transfers.

According to the provider, Elementor’s Data Processing Agreement (DPA) forms part of the contractual terms for Elementor Hosting and also covers its technical hosting and monitoring infrastructure.

Further information is available in the Elementor Data Processing Agreement and the Elementor Sub-processors List.

Technically Necessary Security Functions

The security cookies __cf_bm, _cfuvid and cf_clearance have been observed on our website. These cookies are typically associated with Cloudflare security and bot protection functions. Whether they are set by the hosting infrastructure or by integrated third-party providers depends on the specific technical implementation. They are used in particular to protect against abusive or automated access. Their retention periods depend on the respective function.

2.4 Email Communication, Event Invitations and Community Information

We occasionally send emails through our business email account (for example, Outlook), particularly to communicate with customers and prospective customers about events, community activities and our services. We do not use a recurring HubSpot newsletter for this purpose.

We occasionally send information and invitations concerning events, community activities and our services to customers and prospective customers. Where communication is necessary to perform a contract or take pre-contractual steps, Article 6(1)(b) GDPR is the legal basis. Promotional emails to prospective customers are sent on the basis of consent under Article 6(1)(a) GDPR, which may be given through a checkbox in a HubSpot form. Consent may be withdrawn at any time with future effect. Where existing customers are contacted for advertising purposes without separate consent, the requirements of Section 7(3) of the German Act Against Unfair Competition (UWG) must be met. You may object to promotional communications at any time.

2.5 HubSpot Forms in Pop-ups

We use forms provided by HubSpot on our website. These are primarily displayed in pop-ups after you click a corresponding button. When a form is opened, a connection to HubSpot is established to load and display its contents.

After a HubSpot form is submitted, the information entered is stored in HubSpot as a contact or enquiry and used to handle the request. Depending on the form, this may include your name, email address, company and message. The additional checkbox for notifications is separate from the processing of the requested form data. This privacy policy does not change the existing wording of that checkbox.

Where processing is necessary to take pre-contractual steps or perform a contract, the legal basis is Article 6(1)(b) GDPR. In other cases, Article 6(1)(f) GDPR may apply in particular to handling and responding to your enquiry. Where consent is required for individual processing activities, the legal basis is Article 6(1)(a) GDPR.

We use HubSpot to provide and manage these forms. According to the available account settings, our HubSpot account is assigned to the European Union data-hosting region. According to HubSpot’s contractual documentation, the Data Processing Agreement (DPA) forms part of the HubSpot Customer Terms of Service and also includes provisions governing international data transfers. Processing by HubSpot entities or subprocessors outside the EEA cannot be ruled out solely because EU data hosting is selected. Contact and enquiry data are deleted when no longer required for their purposes and when no retention obligations apply. Necessity is currently reviewed on a case-by-case basis; no fixed periodic deletion schedule is in place.

2.6 Use of Cookies

Cookies and similar technologies may be used on our website. Cookies are small text files stored in your device’s browser. Similar technologies may store or access information on your device or process information about its use.

We use Moove GDPR as a consent-management tool to request and store your choices regarding the categories and services displayed in the banner. You can reopen the cookie or privacy settings through the relevant option on the website. The providers, purposes and technologies listed there must correspond to the website’s actual configuration.

2.6.1 Consent Management

Technically necessary technologies may be used where required to provide the website or a function expressly requested by you. Other cookies and similar technologies requiring consent may only be used after the necessary consent has been obtained. You can change or withdraw your consent with future effect through our cookie or privacy settings. Your selection is stored so that it can be respected on subsequent page visits and consent can be documented.

2.7 Analytics / Marketing

2.7.1 Google Services

We use services provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) on our website. This may also involve transfers of data to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google is certified under the EU–US Data Privacy Framework and is covered by the EU adequacy decision for the United States within the scope of that certification.

(a) Google Analytics

We use Google Analytics 4, which is integrated into our website via Google Tag Manager, to statistically analyze the use of our website. Google Site Kit is used to connect to Google services and display analytics reports in the WordPress dashboard; the Google Analytics tracking code is not inserted by Google Site Kit. The results help us understand the reach and use of our content and improve the website. Our current use does not include Google Ads remarketing.

Google Analytics 4 may process information including page views, interactions, technical browser and device characteristics, and approximate geographic information. Where cookies or similar technologies are used, this takes place only after the relevant consent has been obtained.

Google Analytics 4 processes technical connection information when measurement data are transmitted. According to Google, IP addresses are not logged or stored by Google Analytics 4; for EU traffic, processing takes place through corresponding regional infrastructure. The specific processing depends on the configuration used.

Possible measurement data include in particular:

Page views, interactions, duration of use, technical device and browser information, and approximate location information.

Further processing by Google is governed by the applicable Google privacy terms and the specific configuration of the service.

(b) Legal Basis and Withdrawal of Consent for Google Analytics

We use Google Analytics 4 on the basis of your prior consent (Article 6(1)(a) GDPR and, where applicable, Section 25 of the German Telecommunications Digital Services Data Protection Act (TDDDG)).

You can withdraw your consent at any time with future effect through our website’s cookie or privacy settings.

2.7.2 HubSpot Visitor Tracking

We use website visitor analytics features provided by HubSpot to better understand how visitors use our website and interact with our content, and to improve our marketing and communication activities.

As part of visitor tracking, information about pages visited, interactions with website elements, visit times, browser and device information, and technical connection data may be processed.

In particular, the following cookies may be used:

Cookie	Purpose	Retention Period
hubspotutk	Recognition of returning visitors	Approximately 180 days
__hstc	Visitor and session analytics	Approximately 180 days
__hssc	Management of session information	Approximately 30 minutes
__hssrc	Detection of new sessions	Until the end of the browser session

Depending on the use and configuration of HubSpot, website visit information may also be associated with an existing HubSpot contact record.

HubSpot visitor tracking that requires consent is activated only after you have given your prior consent, in accordance with Article 6(1)(a) of the General Data Protection Regulation (GDPR) and Section 25(1) of the German Telecommunications Digital Services Data Protection Act (TDDDG).

You may withdraw your consent at any time with effect for the future through the cookie or privacy settings on our website.

We use HubSpot as our service provider for this processing. According to the available account settings, our HubSpot account is assigned to the European Union hosting region. However, processing of personal data outside the European Economic Area cannot be ruled out.

Further information about data processing agreements and possible international data transfers can be found in Section 2.5 of this Privacy Policy.

2.8 Webinars

When you participate in webinars, we process your data. For webinar registration and delivery, we may process the following personal data:

• Communication data (for example, your email address, if provided)
• Personal identification details (if provided)
• Company details
• Log files and protocol data
• Metadata (for example, IP address and time of participation).

We generally use Microsoft Teams for occasional webinars and online events. Data processed may include your name, contact and company details, registration information, technical connection data and, during the event, your image, voice and chat contributions.

Webinars may be recorded. Recordings are used internally and may also be published. During registration, we expressly inform participants about recording and possible publication and request their agreement. Publication of identifiable video, audio or chat contributions requires valid, demonstrable consent for that purpose; where necessary, we offer a way to participate without publication of personal contributions.

Registration data are processed to organise and conduct the event; depending on the circumstances, the legal basis is Article 6(1)(b) or Article 6(1)(f) GDPR. Where consent is required, particularly for publication of identifiable contributions, processing is based on Article 6(1)(a) GDPR. Consent may be withdrawn at any time with future effect. Where recordings have already been published, we will then assess the measures needed to remove or anonymise the relevant contributions.

Microsoft Teams is provided by Microsoft. Its use may involve processing by Microsoft and its subprocessors, potentially also outside the EEA in accordance with applicable transfer rules. Recordings are retained only for as long as necessary for the stated event, documentation or publication purposes and provided no statutory retention obligations require otherwise.

3 Rights of Data Subjects

Your rights as a data subject are explained in Section E.

4 Exercising Your Rights and Right to Lodge a Complaint

For questions about the processing of your personal data, or to request access, rectification, restriction, objection, erasure or transfer of data to another organisation, please contact info@networkervc.com.

D. Data Processing

1 Processing Activities

The data affected by individual processing activities, the purposes, legal bases, recipients and, where relevant, transfers to third countries are described below.

1.1 Performance of Contracts and Data Management in Providing Services

When providing our services and initiating or carrying out contractual relationships, we process various data. If you engage us to provide a service, we process your data (where supplied: name, contact details and address) and all information necessary to fulfil the engagement solely to handle and perform the contract. This includes, in particular, appropriate advice and support, correspondence, invoicing, and compliance with accounting and tax obligations.

The legal bases are Article 6(1)(b) GDPR and, where applicable, Article 6(1)(c) GDPR for compliance with our legal obligations.

Where necessary to perform the engagement, your data may be disclosed to third parties. This may include disclosure to supervisory authorities for correspondence or for the establishment, exercise or defence of legal claims.

Where we engage external service providers to deliver our services, they receive personal data only to the extent necessary and in accordance with legal requirements, where appropriate under a data processing agreement.

1.2 External Content on Our Website

Our website may include content from external providers. Depending on the integration, a connection to the provider is established only after you expressly enable the content. The data transferred depend on the service concerned.

We use external content in connection with the following functions:

1.2.1 Embedding YouTube Videos

YouTube videos are embedded on our website. For videos embedded using the tested Elementor video widget with a preview image, a privacy notice appears before loading. Only after an explicit click on “Load YouTube video” does the lightbox containing the YouTube player open. In this process, your IP address and technical connection data may be transmitted to Google. Privacy-enhanced mode is enabled for this integration.

Permission is given through an explicit action for each video. The legal basis for an embedding requiring consent is Article 6(1)(a) GDPR and, where applicable, Section 25 TDDDG. The permission is not stored permanently by the two-click solution used.

Google is certified under the EU–US Data Privacy Framework and, to that extent, is covered by the EU adequacy decision for the United States.

2 Social Media

Below we explain the processing of data in connection with the social media profiles we operate.

2.1 LinkedIn

2.1.1 Joint Controllership for Data Processing

LinkedIn is a service provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Together with LinkedIn, we are joint controllers under the GDPR, in particular Article 4(7), for processing connected with our company profile, especially the “Page Insights” function. When you visit our company profile, personal data are processed by LinkedIn and by us as controllers.

LinkedIn has primary responsibility under the GDPR for processing Page Insights data and fulfils the relevant GDPR obligations for that processing (including Articles 12 and 13, 15–22 and 32–34 GDPR). LinkedIn remains solely responsible for processing personal data relating to Page Insights that falls outside the existing Page Insights Joint Controller Addendum.

The “Page Insights Joint Controller Addendum” is available at: https://legal.linkedin.com/pages-joint-controller-addendum

LinkedIn’s privacy policy is available at: https://www.linkedin.com/legal/privacy-policy

2.1.2 What Data Do We Process and for What Purposes?

Communication and Interaction

Our LinkedIn company profile is intended to enable communication and interaction with users and visitors of the LinkedIn social network. We also provide information about our company and its services.

As the operator of a LinkedIn profile, we may process information you make available as a LinkedIn member. This includes information in your profile, messages you send to us and your interactions with our content, particularly when you share, recommend or comment on our content, contact us or refer to our presence on LinkedIn.

Our legal basis is our legitimate interest in effective communication with LinkedIn users and visitors to our profile and in presenting our company on social media, under Article 6(1)(f) GDPR.

Job Applications

If you submit a job application via LinkedIn or express interest in a position we have offered you, we process the information you provide (for example, name, email address, preferred work location and LinkedIn profile information), your message and application documents solely to handle your application.

The processing of applicant data is based on Section 26(1) of the German Federal Data Protection Act (BDSG), insofar as the processing is necessary for a decision on establishing an employment relationship.

If data are needed after the recruitment process for legal proceedings, we may process them on the basis of our legitimate interests under Article 6(1)(f) GDPR, namely to establish, exercise or defend legal claims.

User Analytics

LinkedIn provides us with information about visits and visitors to our company page through “Page Insights”. LinkedIn creates these statistics to help us better understand and direct our activities. These are aggregated data that do not allow us to identify individual users. LinkedIn is responsible for processing the underlying personal data in Page Insights. We have no access to those personal data other than in aggregated form.

Our legal basis is our legitimate interest in effective communication with LinkedIn users and visitors to our profile and in presenting our company on social media, under Article 6(1)(f) GDPR.

2.1.3 Disclosure of Data and Transfers to the United States

Data collected when you visit our company profile may be transferred to LinkedIn Corporation in the United States and processed there. LinkedIn is certified under the EU–US Data Privacy Framework and is therefore covered by the EU adequacy decision for the United States within the scope of that certification.

Apart from this, we do not disclose data to third parties in operating our company profile.

E. Your Rights as a Data Subject

Unless otherwise stated in the relevant privacy information, you have the following rights:

1 Right of Access

Upon request, you may obtain information about the personal data we hold about you, free of charge, in accordance with applicable law.

2 Rectification, Erasure, Restriction of Processing and Objection

If you no longer agree to the storage of your personal data or if the data are inaccurate, we will arrange for erasure or restriction of processing, or make the necessary corrections, upon a corresponding request and to the extent permitted by law. The same applies where you request that we restrict future processing. In particular, you have a right to object where processing is based on the performance of a task carried out in the public interest or on our legitimate interests, including related profiling. You also have the right to object to processing for direct marketing.

3 Withdrawal of Consent with Future Effect

You may withdraw any consent you have given at any time with future effect. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

4 Data Portability

Where the statutory requirements are met, in particular where processing is based on consent or a contract and is carried out by automated means, you have the right to data portability. Upon request, we will provide the relevant data in a structured, commonly used and machine-readable format so that you can transmit them to another controller.

5 Restriction of Processing

Data for which we cannot identify the data subject, for example because they have been anonymised for analysis, may fall outside the scope of the above rights. Access, erasure, restriction, rectification or portability may be possible if you provide additional information enabling us to identify you.

6 No Automated Decision-Making

We do not subject data subjects to automated individual decision-making within the meaning of Article 22 GDPR. Should this occur in an individual case, we will provide separate information.

7 Exercising Your Rights and Right to Lodge a Complaint

To exercise your rights, please contact info@networkervc.com. You also have the right to lodge a complaint with a competent data protection supervisory authority.

You may also contact a supervisory authority regarding your rights as a data subject.

Version 10/2026