Privacy Policy

This Data Protection Declaration informs you about the scope of the processing of your personal data (“data”).

1. Party responsible for the data processing (“controller”)

The party responsible for the data processing (“controller”) in accordance with the provisions of the General Data Protection Regulation (GDPR) is:
Implementation Partners GmbH
Berberitzenweg 12
60435 Frankfurt am Main
T. +49 173 6749860

2. Contact details of our Data Protection Officer

Sertac Cetiner
Berberitzenweg 12
60435 Frankfurt am Main
T. +49 173 6749860

3. General information about the data processing and about joint processing

We process data in the course of our business and website operations.
This also includes disclosure through the transmission of data to third parties and, where applicable, to so-called third countries outside the European Union (“EU”) and the European Economic Area (“EEA”). Where we transmit data to countries outside the EU or the EEA, we have indicated this accordingly below.
4. Data processing

The individually involved data, processing purposes, legal bases, recipients and, where applicable, transmissions to third countries are listed below:
a) Logfile of website visit
We log your visit to our website. In doing so, we process:

  • Name(s) of our called website(s)
  • Date and time of call
  • Volume of data transferred
  • Browser type, including version
  • Your used operating system
  • Referrer URL (the website visited beforehand)
  • Your IP address
  • The requesting provider

  • The legal basis for data processing is point (f) of Article 6 (1) GDPR, namely our overriding legitimate interest in the ongoing provision and security of our website.

    The logfile will be erased after seven days, unless it is required to demonstrate or investigate specific legal violations that have become known within the retention period.

    b) Hosting via IONOS
    We use the services of web hosting providers in order to provide our online presence; these web hosting providers process the above-mentioned data, as well as all data that need to be processed in connection with the operation of this website (logfile of the website visit), under commission by us.
    The legal basis for data processing is point (f) of Article 6 (1) GDPR, namely our overriding legitimate interest in the provision of our website.
    For our hosting, we use service provided by IONOS, IONOS Inc. Privacy Rights
    ​​Two Logan Square, 100 N 18th St, Ste 400, Philadelphia, PA 19103.

    The following data is collected from website visitors, and is immediately anonymized as the data is collected:

  • Referrer (previously visited website)
  • Requested website or file
  • Browser type and browser version
  • Operating system used
  • Device type used
  • Time of access
  • IP address in anonymized form (used only to determine the location of access)

  • Additionally, processing by IONOS SiteAnalytics takes place.

    c) Contacting us

    If you contact us, the following data that you provide us will be processed for the purpose of dealing with and handling your inquiry: name, contact details and – if provided by you – your message.
    The legal bases for the data processing are point (b) of Article 6 (1) GDPR, namely our obligation to perform a contract and/or to fulfill our pre-contractual obligations, and/or point (f) of Article 6 (1) GDPR, namely our overriding legitimate interest in processing your inquiry.

    d) Contacting us in relation to job applications

    If you contact us to send us a job application, e.g. by email or via a contact form, the data you provide (e.g. name, email address, desired location, etc.), your message and the submitted job application documents will be processed exclusively for the purpose of handling and dealing with your application inquiry.

    The legal basis for data processing is primarily Section 26 of the German Data Protection Act (Bundesdatenschutzgesetz, BDSG). In accordance with this, it is permissible to process data in connection with making a decision on the establishment of an employment relationship.

    Should the data possibly be needed for legal prosecution after completion of the application process, the legal basis for further processing is point (f) of Article 6 (1) GDPR, namely the safeguarding of our legitimate interest in the exercise and/or defense of legal claims.

    e) Use of cookies

    Our website uses so-called cookies. Cookies are small text files that are stored on your end device (PC, smartphone, tablet, etc.) and saved by your browser.
    Further information about the specific cookies we use, their providers and purposes can be found in our consent management platform (which can be called up by clicking the fingerprint icon at the lower left of the website). There you can give your consent to the services concerned, and later withdraw or adjust your consent settings.

    f) Our consent banner

    We use a consent banner (consent management platform) to document your selection of certain data processing processes and to fulfill our statutory data protection obligations. When you visit our website, your cookie preferences are requested via a consent banner. We then set a cookie in which data on your given consents and withdrawn consents are stored. The legal basis for the data processing is point (c) of Article 6 (1) GDPR, namely fulfillment of our legal obligations.

    g) Analytics / marketing

    aa) Google services

    Our website uses various services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). In doing so, data may possibly also be transmitted to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 in the USA.

    An adequacy decision of the EU Commission does not exist for data transmissions to the USA. Google ensures an adequate level of data protection through its observance of EU standard contractual clauses. We can provide you with a copy of the EU standard contractual clauses upon request. For this, please contact

    Google Analytics

    Our website uses the Google Analytics tracking tool of Google. We use Google Analytics to evaluate your use of the website, to compile reports on website activities and to provide other services associated with the use of the website, and thereby improve user friendliness.
    When Google Analytics is used, interactions of website visitors are primarily recorded and systematically evaluated with the help of cookies.
    We use Google Analytics with the extension “anonymizeIp()”. This truncates IP addresses within the member states of the EU or EEA. If data are transmitted to Google’s servers in the USA, the full IP address is only transmitted in exceptional cases and truncated there. A direct reference to a person can therefore generally be ruled out. In particular, an assignment to the called computer or to the end device of the website visitor is no longer possible.

    The following data are processed through the use of Google Analytics:

  • Three bytes of the IP address of the called system of the website visitor (anonymized IP address)
  • the called website called
  • the website from which the user reached the accessed page of our website (referrer)
  • the subpages accessed from the website
  • the time spent on the website
  • the frequency with which the website is accessed

  • Google declares that it will not under any circumstances combine your IP address with any other data held by Google.

    Google Tags / Remarketing/Retargeting

    Our website uses so-called tracking cookies from Google. When you visit our website, permanent cookies are used to store information about the products you viewed on our website, as well as the third-party ads and web pages through which users reach our website. If you subsequently visit a partner website, we can display customized advertising for you based on the items you viewed on our website.

    Google Ads

    Our website uses Google Ads, an online advertising program of Google. This employs so-called conversion tracking. If you click on an ad placed by Google, a cookie is set. This cookie loses its validity after 30 days and is not used to personally identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page.
    The data collected using the conversion cookie are used to compile statistics for Ads customers who have opted in to conversion tracking.

    Legal basis and withdrawal

    The legal basis for the data processing is point (a) of Article 6 (1) GDPR, namely your prior given consent.
    You can withdraw your consent at any time with effect for the future by adjusting your preferences in our consent management platform (which can be called up by clicking the fingerprint icon at the lower left of the website).

  • bb) Facebook Custom Audiences (Pixel/Cookies)

  • Our website uses a so-called tracking pixel of Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, a subsidiary of Facebook Inc., 1601, Willow Road Menlo Park, CA 94025, USA. We use Facebook Pixel to track the success of our own Facebook advertising campaigns and to optimize the relaying of Facebook advertising campaigns to interested target groups.

    When you click on a Facebook ad or visit our website, the Facebook Pixel on our website is used to store a cookie on your end device. The cookie processes data about whether you reached our website via a Facebook ad, and allows us to analyze the user’s behavior until the purchase is completed. This allows us to track the success rate of our Facebook advertising campaigns. In addition, the Facebook Pixel processes data about the fact that you have visited our website, and allows the ads that are relayed on Facebook to be customized to your interests.

    The Facebook Pixel integrated into our website establishes a direct connection to Facebook’s servers when you visit our website. The information that the cookie generates about your use of this website (including your IP address) is transmitted to Facebook in the USA.

    The collected data are anonymous for us and do not allow us to draw any conclusions about the user. If you are registered with Facebook, Facebook can assign the collected information to your account. Even if you do not have a Facebook account or are not logged in when you visit our website, it is possible for Facebook to process and store your IP address and other identification data.
    You can withdraw your consent to data processing by Facebook Pixel for our web domain at any time with future effect by adjusting your preferences in our consent management platform (which can be called up by clicking the fingerprint icon at the lower left of the website).

    The legal basis for the data processing is point (a) of Article 6 (1) GDPR, namely your prior given consent.

  • cc) Activity

  • This feature only records activities of a site’s registered users, and the retention duration of activity data will depend on the site’s plan and activity type.

    Data Used: To deliver this functionality and record activities around site management, the following information is captured: user email address, user role, user login, user display name, and local user IDs, the activity to be recorded, the site ID of the site on which the activity takes place, the site’s Jetpack version, and the timestamp of the activity. Some activities may also include the actor’s IP address (login attempts, for example) and user agent.

    Activity Tracked: Login attempts/actions, post and page update and publish actions, comment/pingback submission and management actions, plugin and theme management actions, widget updates, user management actions, and the modification of other various site settings and options. Retention duration of activity data depends on the site’s plan and activity type. See the complete list of currently-recorded activities (along with retention information).

    Data Synced (?): Successful and failed login attempts, which will include the actor’s IP addData Synced (?)ress and user agent.

  • dd) Google Analytics

  • This feature is only available to sites on a Jetpack Security or Jetpack Complete plan.

    Data Used: Please refer to the appropriate Google Analytics documentation for the specific type of data it collects. For sites running WooCommerce (also owned by Automattic) and this feature simultaneously and having all purchase tracking explicitly enabled, purchase events will send Google Analytics the following information: order number, product id and name, product category, total cost, and quantity of items purchased. Google Analytics does offer IP anonymization, which can be enabled by the site owner.

    Activity Tracked: This feature sends page view events (and potentially video play events) over to Google Analytics for consumption. For sites running WooCommerce-powered stores, some additional events are also sent to Google Analytics: shopping cart additions and removals, product listing views and clicks, product detail views, and purchases. Tracking for each specific WooCommerce event needs to be enabled by the site owner.

  • ee) Gravatar Hovercards

  • Data Used: This feature will send a hash of the user’s email address (if logged in to the site or — or if they submitted a comment on the site using their email address that is attached to an active Gravatar profile) to the Gravatar service (also owned by Automattic) in order to retrieve their profile image.

    ff) Repeat Visitor Block
    Data Used:The Repeat Visitor block records page views by setting a cookie named `jp-visit-counter` in the visitor’s browser, which is incremented on each visit. This cookie is stored only in the browser and not recorded in our databases.

  • gg) Secure Sign On

  • This feature is only accessible to registered users of the site with accounts.

    Data Used: User ID (local site and, role (e.g. administrator), email address, username and display name. Additionally, for activity tracking (see below): IP address, user ID, username, site ID and URL, Jetpack version, user agent, visiting URL, referring URL, timestamp of event, browser language, country code.

    Activity Tracked: The following usage events are recorded: starting the login process, completing the login process, failing the login process, successfully being redirected after login, and failing to be redirected after login. Several functionality cookies are also set, and these are detailed explicitly in our Cookie documentation.

    Data Synced (?): The user ID and role of any user who successfully signed in via this feature.

  • hh) Jetpack Stats

  • Data Used: IP address, user ID (if logged in), username (if logged in), user agent, visiting URL, referring URL, timestamp of event, browser language, country code.

    Important: The site owner does not have access to any of this information via this feature. For example, a site owner can see that a specific post has 285 views, but he/she cannot see which specific users/accounts viewed that post. Stats logs — containing visitor IP addresses and usernames (if available) — are retained by Automattic for 28 days and are used for the sole purpose of powering this feature.

    Activity Tracked: Post and page views, video plays (if videos are hosted by, outbound link clicks, referring URLs and search engine terms, and country. When this feature is enabled, Jetpack also tracks performance on each page load that includes the JavaScript file used for tracking stats. This is exclusively for aggregate performance tracking across Jetpack sites in order to make sure that our plugin and code is not causing performance issues. This includes the tracking of page load times and resource loading duration (image files, JavaScript files, CSS files, etc.). The site owner has the ability to force this feature to honor DNT settings of visitors. By default, DNT is currently not honored.

    5. Duration of data storage

    We store personal data only as long as is necessary for the designated processing purposes or until you withdraw your given consent. Where statutory retention obligations must be observed, the storage period for certain data can be up to 10 years, regardless of the designated processing purposes.

    6. Your rights as a data subject

    a) Right to information

    Upon request, we will provide you at any time and at no charge with information about all the personal data that we have stored about you.

    b) Right to rectification, erasure, restriction of processing (blocking), right to object

    If you no longer consent to the storage of your personal data or if these data have become inaccurate, we will arrange for your data to be erased or blocked, or to be rectified as necessary (provided that this is possible under applicable law), as per your instructions. The same applies if we are to process data only in a restrictive manner in the future. You have a right to object, in particular, in cases where your data are required due to the performance of a task that is in the public interest or the data processing is based on our legitimate interest, as well as in the event of profiling based on this. You also have such a right to object if your data are processed for the purpose of direct marketing.

    c) Right to withdraw consents with effect for the future

    You may withdraw given consents at any time with effect for the future. Your withdrawal does not affect the lawfulness of the processing up until the time of the withdrawal.

    d) Right to data portability

    Where data are processed on the basis of a contract, pre-contractual negotiations, consent or with the help of automated processes, you have the right to data portability. Upon request, we will provide you with your data in a common, structured and machine-readable format to enable you to transmit the data to another controller if so desired.

    e) Right to restrict processing

    Data for which we are unable to identify the data subject, e.g. if they have been anonymized for analysis purposes, are not covered by the above rights. The right to information, erasure, blocking, rectification and transmission to another company may be possible for these data if you provide us with additional information that allows us to associate them with to you.

    f) Exercising your data subjects’ rights, right to lodge a complaint

    If you have any questions regarding the processing of your personal data, or wish to obtain information, or rectify, block, object to or erase data, or if you wish to have your data transmitted to another company, please contact

    You also have the option of lodging a complaint with a supervisory authority in regard to your data subject’s rights.



    Frankurt (Germany)
    Implementation Partners, GmbH
    Theodor-Heuss-Allee 112
    60486 Frankfurt am Main

    Prague (Czech Republic)
    Implementation Partners, GmbH
    Na Strži 1702/65
    140 00Prague
    Czech Republic

    Ankara (Turkey)
    Söğütözü Mah. Söğütözü Cad. No:2/B Koç
    Kuleleri Daire 9
    06530 Çankaya/ANKARA

    Izmir (Turkey)
    Zafer SB Mah. Nilüfer Sk. No: 40/21
    C Blok Modül 18
    35410 Gaziemir Izmir

    Hyderabad (India)
    1st Floor, Jyothi Pinacle,F959+4HG,
    Hitech City Rd, Laxmi Cyber City,
    Whitefields, Kondapur,
    Telangana 500081