We, twinwin, operate the website and and collect certain data from our visitors and customers as necessary. In the following privacy policy, you will learn what we do with your data, so-called personal data, and why we do it. We will also tell you how we protect your data, when the data will be deleted and what rights you have thanks to data protection.

Who can I contact?

Responsible for this website is

twinwin GmbH
c/o Bauermeister
Boddinstr. 24a
12053 Berlin

Online presences




E-Mail (Datenschutz):

You can reach our data protection officer or another data protection-related contact via these contact details. Please contact us at any time if you have specific questions about your data, its deletion or your rights.

What are my rights?

You can contact us at any time if you have questions about your data protection rights or wish to exercise your rights below:

  • Right of withdrawal according to Art. 7 para. 3 DSGVO (e.g. you can contact us if you want to cancel a previously given consent to a newsletter)
  • Right to information according to Art. 15 DSGVO (e.g. you can contact us if you want to know which data we have stored about you)
  • Correction according to Art. 16 DSGVO (e.g. you can contact us if your e-mail address has changed and you want us to replace the old e-mail address)
  • Deletion according to Art. 17 DSGVO (e.g. you can contact us if you want us to delete certain data that we have stored about you)
  • Restriction of processing according to Art. 18 DSGVO (e.g. you can contact us if you would like us not to delete your e-mail address but only to use it for sending absolutely necessary e-mails).
  • Data portability according to Art. 20 DSGVO (e.g. you can contact us to receive your data stored with us in a compressed format, e.g. because you want to make the data available to another website).
  • Objection according to Art. 21 DSGVO (e.g. you can contact us if you do not agree with one of the advertising or analysis procedures specified here).
  • Right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 (1) DSGVO (e.g. you can also contact the data protection supervisory authority in your federal state directly in the event of complaints)

Competent supervisory authority

The data protection supervisory authority responsible for us is:

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstraße 219
10969 Berlin

Privacy policy

How is your personal data protected?

We will take all reasonable and appropriate measures to protect the personal information we store from misuse, loss or unauthorized access. To this end, we have taken a number of technical and organizational measures. This includes measures to deal with any suspected data breaches.

If you suspect that your personal information has been misused, lost or accessed without authorization, please let us know as soon as possible by contacting us using the contact details above!

Legal basis for data processing

We only collect and process your personal data if we are permitted to do so on the basis of a legal basis. In addition to your express consent, other legal bases may be considered. If the processing is based on your consent, Art. 6 (1) lit. a EU General Data Protection Regulation (DSGVO) serves as the legal basis for the processing of your data.

The processing of personal data that is necessary for the fulfillment of the user contract serves Art. 6 (1) lit. b DSGVO as the legal basis.

If processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.If the processing is necessary to protect a legitimate interest or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing. If processing is carried out on the basis of such a balancing of interests, you have the right to object to this data processing provided that you have special reasons for this and we cannot demonstrate any compelling reasons for the processing that are worthy of protection.

You will find the relevant legal basis, if necessary, for individual data processing at the end of the respective descriptions of the data processing.

If we use contracted service providers for individual functions of our offer or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. Insofar as we cooperate with corresponding service providers, we have carefully selected them with regard to compliance with the legal requirements for data protection and data security and have concluded order processing agreements with them that comply with the requirements of Art. 28 DSGVO. If the service providers are based outside the EU, we ensure that suitable guarantees exist in accordance with Art. 46 of the GDPR that an appropriate level of data protection is provided by the processor. For example, certification under the EU-US Privacy Shield or so-called EU standard data protection clauses may be considered. We refer to the appropriate guarantees at the relevant points.

Deletion of data and storage period

Unless otherwise stated, we will delete your data as soon as it is no longer required, e.g. your e-mail address after unsubscribing from our newsletter. Your data will also be blocked or deleted if a storage period prescribed by law expires, unless there is a need for further storage of the data for the conclusion or performance of a contract. Certain data may have to be stored longer for legal reasons. You can, of course, request information about the stored data at any time.

Deletion of data and storage period

If you merely want to browse our website, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website, first and foremost:

  • IP address (e.g. 95.91.215.example or 2a02:8109:9440:1198:bdb1:551f:
  • Approximate location based on IP range (e.g. Berlin & surroundings)
  • Internet provider (e.g. Kabel Deutschland or Deutsche Telekom)
  • Internet speed (e.g. 120 Mbit)
  • Date and time (e.g. 11:45 on 25.05.2018)
  • Last visited website (e.g.
  • Browser (e.g. Chrome or Safari)
  • Operating system (e.g. Mac OS)
  • Hardware (e.g. Intel processor)

As a protective measure in favor of your privacy, we delete or anonymize the IP address after your visit to our website. Thus, the other technical data can no longer be traced back to you and only serve anonymous, statistical purposes for the optimization of our website. The purpose of the temporary storage of the data is, on the one hand, the technical necessity for establishing the connection and the correct, error-free display of our website. The IP address and the technical data already mentioned are necessary to display the website, to prevent display problems for visitors and to correct error messages. The legal basis is the so-called legitimate interest, which has been examined in the context of the aforementioned protective measures and in accordance with the European data protection requirements from Art. 6 (1) lit. f DSGVO.

Use of the service/ information for the examination of the facts

In order to use our service and to have their facts assessed, the provision of personal data from you and possibly the employees is required. We will protect this personal data in the best possible way and according to the state of the art and only process it for the purposes specifically described and intended for this purpose. If the provision of personal data is not required, no information is requested. In some cases, it is necessary for the assessment to provide special types of data within the meaning of Art. 9 DSGVO (such as information on health), in order to be able to assess the facts of the individual case.

The following data must be provided by you and about the employees:

  • Personal master data
  • Contract master data
  • Billing data, payment data
  • Employee data


If you are interested in news about our company or our product, you can subscribe to our newsletter. You will then receive an e-mail in which you must click on a link to confirm receipt of the newsletter. We will then store your e-mail address until you unsubscribe from the newsletter. For this purpose, you will find a corresponding unsubscribe link in every e-mail of our newsletter. The newsletter is delivered by a specialized service provider.

As a protective measure, we request the so-called "double opt-in" to ensure that the e-mail address entered actually belongs to you. Furthermore, we have concluded a data protection contract (order processing) with the commissioned service provider. You also have the option to unsubscribe from the newsletter at any time and thus delete your e-mail address from the service provider's database. The purpose of the data collection is the delivery of the newsletter to your personal e-mail address in order to comply with your request for news about our company or our products. The legal basis is your consent in accordance with the European data protection requirements from Art. 6 para. 1 lit. a DSGVO.


Our website sometimes uses so-called cookies. Cookies are small text files that are usually stored in a folder of your browser. Cookies contain information about the current or last visit to the website:

  • Website name
  • Cookie expiration date
  • Any value

If cookies do not contain an exact expiration date, they are only temporarily stored and automatically deleted as soon as you close your browser or restart the terminal device. Cookies with an expiration date remain stored even if you close your browser or restart the terminal device. Such cookies are only removed on the specified date or when you delete them manually.

We use the following three types of cookies on our website:

  • Required cookies (we need these, e.g. to display the website correctly for you and to cache certain settings).
  • Function and performance-related cookies (these help us to evaluate e.g. technical data of your visit and thus to avoid error messages)
  • Advertising and analytics cookies (these ensure that, for example, advertising for shoes is displayed if you have previously searched for shoes).

You can configure, block and delete cookies in your browser settings. If you delete all cookies from our website, some functions of the website may not be displayed correctly. Helpful information and instructions for common browsers are provided by the Federal Office for Information Security:

Google Fonts

Google Fonts( from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), a font collection from Google, are used to visually improve the typeface. These fonts are transferred to your browser's storage folder and activated when you access this website or other websites. If this is not supported, the text on the website will only be displayed in a standard font. To enable this, a request is sent to domains such as or, which contains your IP address for technical reasons. However, your data will not be merged with other data or traced back to you personally.

As a protective measure, we have assured ourselves that by retrieving the font collection from Google, no merging of data with other Google offerings will occur, for example, if you have a Google user account. English information on data protection at Google Fonts confirms this( In addition, the high security standards of the Google platform and the associated privacy policy of Google apply( Since Google is based in the USA and thus a so-called third country, further guarantees are required to ensure an appropriate European level of data protection. Google has been certified under the so-called EU-US Privacy Shield and has thus demonstrated an appropriate level of data protection( The purpose of the data transfer is the correct display of the fonts in the form we set. The IP address is required to establish a connection with Google's servers in order to download the font collection if it is not already stored on the end device. The legal basis is the so-called legitimate interest, which has been examined in order to pursue the purpose and within the framework of the aforementioned protective measures and in accordance with the European data protection requirements from Art. 6 (1) lit. f DSGVO.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses the advertising and analysis cookies described above to analyze our website with regard to your usage behavior. The information generated by cookies about your use of this website will be transmitted to and stored by Google on servers in the United States. However, your IP address is shortened before the usage statistics are analyzed, so that no conclusions can be drawn about your person. For this purpose, Google Analytics on our website has been extended by the code "anonymizeIp" to ensure anonymized collection of IP addresses. Google will use the anonymized information obtained through the cookies to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

You can also configure your browser to reject cookies, or you can prevent the collection and analysis of data by Google by downloading and installing a browser plugin from Google.

As a protective measure, we use the anonymization procedure offered by Google, whereby a subsequent evaluation of the data is not based on your person, but only on a statistical basis. In addition, the high security standards of the Google platform and the associated privacy policy of Google apply. We have also concluded a special data protection agreement (order processing) with Google, which stipulates the protection of your data through technical and organizational protective measures. Since Google is based in the USA and thus a so-called third country, further guarantees are required to ensure an adequate European level of data protection. Google has been certified under the so-called EU-US Privacy Shield and has thus demonstrated an appropriate level of data protection(see here). Thepurpose of using Google Analytics is the anonymized analysis of your usage behavior on our websites. The insights gained from this help to improve our offer. The legal basis is the so-called legitimate interest, which has been examined in order to pursue the purpose and within the framework of the aforementioned protective measures and in accordance with the European data protection requirements from Art. 6 (1) lit. f DSGVO.

Google Remarketing

Our website uses Google Remarketing. This service uses cookies and similar technologies to show you individualized advertising messages on websites that work with Google. Cookies and comparable technologies are also used to perform the analysis of website usage, which forms the basis for the creation of the interest-based advertisements. The data generated in this context may be transferred by Google to a server in the USA for analysis and stored there.

If you use a Google account, Google may, depending on the settings stored in the Google account, link your web and app browsing history to your Google account and use information from your Google account to personalize ads. If you do not want this association with your Google account, it is necessary that you log out of Google before calling our contact page.

As shown above, you can configure your browser to reject cookies, or you can prevent the collection of data generated by the cookies and related to your use of this website, as well as the processing of this data by Google, by accessing the ad preferences and setting the switches for personalization to "Off". Alternatively, you can object to the processing by visiting the above-mentioned website of TRUSTe and activating the deactivation switch for the provider "Google".

Google Conversion Tracking

We use Google Conversion Tracking of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: "Google") on our website to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. In the process, Google Adwords sets a cookie on your computer if you have accessed our website via a Google ad.

These cookies lose their validity after 30 days. If the user visits certain pages of the AdWords customer's website and the cookie has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page.

Each AdWords customer receives a different cookie. Cookies can therefore not be tracked across AdWords customers' websites. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. We learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, you will not receive any information that personally identifies users.

If you do not wish to participate in the tracking process, you can also refuse the setting of a cookie required for this - for example, via a browser setting that generally disables the automatic setting of cookies. You can also disable cookies for conversion tracking by setting your browser to block cookies from the domain "".


We also use the service of HubSpot. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.

This is an integrated software solution that we use to cover various aspects of our online marketing and business operations. These include: Email Marketing (newsletters as well as automated mailings, e.g. to provide downloads), Social Media Publishing & Reporting, Reporting (e.g. traffic sources, hits, etc. ...), Contact Management (e.g. user segmentation & CRM), Landing Pages, Contact Forms, Inquiry Data Management.

Our sign-up service allows visitors to our website to learn more about our company, download content, and provide their contact information and other demographic information. This information, as well as our website content, is stored on servers operated by our software partner HubSpot. It may be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. All information we collect is subject to this privacy policy. We use all collected information exclusively to optimize our marketing measures.

Furthermore, to improve the user experience on our website, we use HubSpot's live chat service "Messages" (round chat icon at the bottom right of the screen) for sending and receiving messages on some subpages. Upon consent and use of this function, the following data is transmitted to HubSpot's servers:

  • Content of all sent and received chat messages
  • Context information (e.g. page where the chat was used)
  • Optional: e-mail address of the user (if provided by the user via chat function)

The legal basis for the use of the services of Hubspot is Art. 6 I f DS-GVO - legitimate interest. Our legitimate interest in the use of this service is the optimization of our marketing measures and the improvement of our service quality on the website.

HubSpot is certified under the terms of the "EU - U.S. Privacy Shield Framework" and is subject to TRUSTe 's Privacy Seal and the "U.S. - Swiss Safe Harbor" Framework.

More information about HubSpot's privacy policy "More information from HubSpot regarding the EU privacy policy "More information about the cookies used by HubSpot can be found here&here "

If you generally do not want HubSpot to collect data, you can prevent the storage of cookies accordingly at any time through your browser settings or use the following opt-out link: Hubspot Opt-Out Link.

Privacy policy status: June 2020