Privacy Policy
Foreword
We, tilt SMEs Ltd. (hereinafter collectively referred to as ‘the company’, “we” or ‘us’) take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our company.
According to the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: ‘GDPR’), there are obligations to ensure the protection of personal data of the data subject (we also refer to you as the data subject as ‘customer’, ‘user’, “you” or ‘data subject’).
Insofar as we decide, either alone or jointly with others, on the purposes and means of data processing, this includes, in particular, the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Articles 13 and 14 GDPR). With this declaration (hereinafter: ‘data protection information’), we inform you about how we process your personal data.
A. General Information
1. Definitions
Based on Art. 4 GDPR, this data protection notice is based on the following definitions:
– ‘Personal data’ (Art. 4 No. 1 GDPR) is any information relating to an identified or identifiable natural person (‘data subject’). A person is identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, an online identifier, location data or by means of information about their physical, physiological, genetic, mental, economic, cultural or social identity characteristics. Identifiability may also be achieved by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data).
– ‘Processing’ (Art. 4 No. 2 GDPR) is any operation involving personal data, whether or not with the aid of automated (i.e. technology-based) procedures. This includes, in particular, the collection (i.e. procurement), recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning, combining, restricting, erasing or destroying personal data, as well as changing the purpose or objective for which the data was originally processed.
– ‘Controller’ (Art. 4 No. 7 GDPR) is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
– ‘Third party’ (Art. 4 No. 10 GDPR) is any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorised to process personal data; this also includes other legal entities belonging to the group.
– ‘Processor’ (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service providers). In terms of data protection law, a processor is not a third party.
– ‘Consent’ (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the Controller
The controller within the meaning of Article 4 No. 7 GDPR responsible for processing your personal data is:
tilt SMEs GmbH
Rollbergstraße 28a
12053 Berlin
contact@tiltsmes.org
Further information about our company can be found in the imprint on our website: https://www.tiltsmes.org/imprint.
3. Contact Details of the Data Protection Contact
We are not legally obliged to appoint a data protection officer. If you have any questions about data protection, please do not hesitate to contact us at contact@tiltsmes.org.
4. Legal Bases for Data Processing
By law, any processing of personal data is prohibited in principle and is only permitted if the data processing falls under one of the following justifications:
– Art. 6(1)(a) GDPR (‘Consent’): Where the data subject has freely given, specifically, informed and unambiguous consent for the processing of his or her personal data for one or more specific purposes;
– Art. 6(1)(b) GDPR: Where processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
– Art. 6(1)(c) GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
– Art. 6(1)(d) GDPR: If processing is necessary to protect the vital interests of the data subject or another natural person;
– Art. 6(1)(e) GDPR: If processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
– Art. 6(1)(f) GDPR (‘legitimate interests’): If processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which are likely to result in the personal data being erased or restricted (in particular where the data subject is a child).
We indicate the applicable legal basis for each of the processing operations we carry out below. Processing may also be based on several legal bases.
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 Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, if special categories of data are processed in accordance with Article 9(1) GDPR. 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(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g. via device fingerprinting), data processing is also carried out on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if it is necessary to fulfil a legal obligation on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.
5. Data Deletion and Storage Period
For the processing operations we carry out, we specify below how long the data is stored by us and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in the European Economic Area (EEA), subject to any transfer in accordance with the provisions set out below on ‘Cooperation with processors’ and ‘Requirements for the transfer of personal data to third countries’.
However, storage may continue beyond the specified period in the event of an (imminent) legal dispute with you or other legal proceedings, or if storage is required by legal provisions to which we are subject as the controller (e.g. Section 257 of the German Commercial Code (HGB), Section 147 of the German Fiscal Code (AO)). When the storage period prescribed by law expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this.
6. Data Security
We use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of processing as well as the existing risks of a data breach (including its likelihood and impact) for the data subject. Our security measures are continuously improved in line with technological developments.
7. Recipients of Personal Data
As part of our business activities, we work with various external parties. In some cases, this requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the fulfilment of a contract, if we are legally obliged to do so (e.g. transfer of data to tax authorities), if we have a legitimate interest in the transfer pursuant to Art. 6 (1) lit. f GDPR, or if another legal basis permits the transfer of data. When using processors, we only transfer our customers' personal data on the basis of a valid contract for data processing. In the case of joint processing, a contract for joint processing is concluded.
8. Cooperation with processors
We use external domestic and foreign service providers to conduct our business transactions (e.g. in the areas of IT, logistics, telecommunications and marketing). These service providers only act in accordance with our instructions and are contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.
If we pass on your personal data to our subsidiaries or if our subsidiaries pass on your personal data to us (e.g. for advertising purposes), this is done on the basis of existing data processing agreements.
9. Requirements for the transfer of personal data to third countries
Within the scope of our business relationships, your personal data may be passed on or disclosed to third-party companies. These may also be located outside the EEA, i.e. in third countries. Such processing is carried out exclusively for the purpose of fulfilling contractual and business obligations and maintaining your business relationship with us. We will inform you of the respective details of the transfer below in the relevant sections.
The European Commission certifies that some third countries have data protection standards comparable to those of the EEA through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions are available on the European Commission's website). In other third countries to which personal data may be transferred, however, there may not be a consistently high level of data protection due to a lack of legal provisions. Where this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognised codes of conduct.
10. No Automated Decision-Making (including Profiling)
We do not intend to use personal data collected from you for automated decision-making (including profiling).
11. No Obligation to Provide Personal Data
We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are not legally or contractually obliged to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in relation to the products we offer, as described below, you will be notified separately.
12. Your Rights
You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided in section A.(2) above. As a data subject, you have the right:
to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you may obtain information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if it was not collected by us, and the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;
to request the immediate correction of inaccurate data or the completion of your data stored by us in accordance with Art. 16 GDPR;
to request the erasure of your data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims;
to request the restriction of the processing of your data in accordance with Art. 18 GDPR, unless the accuracy of the data is disputed by you or the processing is unlawful;
pursuant to Art. 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request its transfer to another controller (‘data portability’);
pursuant to Art. 21 GDPR, to object to data collection in specific cases and to direct marketing (Art. 21 GDPR), provided that the processing is based on Art. 6(1)(e) or (f) GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either cease or adapt the data processing or point out to you our compelling legitimate grounds on the basis of which we will continue the processing;
In accordance with Art. 7(3) GDPR, you may revoke your consent at any time – i.e. your voluntary, informed and unambiguous declaration of intent, made clear by means of a statement or other unequivocal affirmative action, that you agree to the processing of the personal data concerned for one or more specific purposes – if you have given such consent. As a result, we may no longer continue the data processing that was based on this consent in the future;
pursuant to Art. 77 GDPR, to lodge a complaint with a data protection supervisory authority about the processing of your personal data in our organisation; and
pursuant to Art. 79 GDPR, to obtain judicial protection before the ordinary courts and the labour courts, in particular if we refuse to act on the request of the data subject pursuant to Art. 12(5) GDPR.
13. Objection to Advertising Emails
The use of contact details published within the scope of the imprint obligation for sending unsolicited advertising and information material by third parties is hereby expressly prohibited. The operators of the website expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example via spam emails.
14. Changes to the privacy policy
Changes to the privacy policy As part of the ongoing development of data protection law and technological or organisational changes, our privacy policy is regularly reviewed to determine whether it needs to be amended or supplemented. You will be informed of any changes in particular on our website. This privacy policy is current as of September 2025.
B. Visiting the websites
When you visit our websites, your personal data may be processed. When you use the websites, we may collect, store and further process the following categories of personal data:
1.Data Processing, Purpose and Legal Basis
When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:
the page from which the page was requested (so-called referrer URL)
the name and URL of the requested page
the date and time of the request
the description of the type, language and version of the web browser used
the IP address of the requesting computer, which is shortened so that it can no longer be traced back to a specific person
the amount of data transferred
the operating system
a message indicating whether the request was successful (access status/HTTP status code)
the GMT time zone difference
The log data is processed for statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (the legal basis is Art. 6(1)(1)(f) GDPR). The stored information is deleted after seven days, unless there is reasonable suspicion of unlawful use, which requires further investigation. It is not possible for us to identify you based on the stored information. Therefore, Articles 15 to 22 GDPR do not apply in accordance with Art. 11(2) GDPR, unless you provide further information that enables your identification.
Enquiries by email, telephone or fax
If you contact us by e-mail, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of processing your enquiry.
This data is processed on the basis of Article 6(1)(b) of the GDPR, provided that your enquiry 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 enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested.
Contact form data
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR, provided that your enquiry 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 enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested.
2.Duration of data processing
Your data will only be processed until you request us to delete it, revoke your consent to its storage, or as necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply in this regard. With regard to the use and storage period of cookies, please note the points mentioned there and the cookie declaration.
Third parties employed by us will store your data on their system for as long as is necessary in connection with the provision of services for us in accordance with the respective order.
3.Transfer of personal data to third parties; legal basis
The following categories of recipients, who are usually processors, may have access to your personal data:
– Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data centre services, payment processing, IT security). The legal basis for the transfer is then Art. 6(1)(b) or (f) GDPR, unless they are processors;
– Government agencies/authorities, insofar as this is necessary to fulfil a legal obligation. The legal basis for the transfer is then Art. 6(1)(c) GDPR;
– Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors or supervisory authorities). The legal basis for the transfer is then Art. 6(1)(b) or (f) GDPR.
Furthermore, we only disclose your personal data to third parties if you have given your express consent in accordance with Art. 6(1)(a) GDPR or if it is necessary on the basis of the contract with you in accordance with Art. 6(1)(b) GDPR.
4.Hosting and Content Delivery Networks (CDN)
We host the content of our website with the following providers:
Amazon CloudFront CDN
We use the Amazon CloudFront CDN content delivery network. The provider is Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg (hereinafter referred to as ‘Amazon’).
Amazon CloudFront CDN is a globally distributed content delivery network. Technically, the transfer of information between your browser and our website is routed via the content delivery network. This enables us to increase the global accessibility and performance of our website.
The use of Amazon CloudFront CDN is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6(1)(f) GDPR).
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.
Further information on Amazon CloudFront CDN can be found here: https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf.
The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards when processing data in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5776.
Order processing
We have concluded an order processing agreement (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.
Contact form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 (1) (b) GDPR, provided that your enquiry 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 enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.
Social media
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Each time a page on this website containing elements from LinkedIn is accessed, a connection to LinkedIn's servers is established. LinkedIn is informed that you have visited this website with your IP address. If you click on the LinkedIn ‘Recommend’ button and are logged into your LinkedIn account, LinkedIn can associate your visit to this website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the data transmitted or its use by LinkedIn.
The use of this service is based on your consent in accordance with Art. 6 (1) lit. a GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-schweiz?lang=de
Further information on this can be found in LinkedIn's privacy policy at: https://www.linkedin.com/legal/privacy-policy.
The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the US that aims to ensure compliance with European data protection standards when data is processed in the US. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5448.
C. Use of cookies, plugins and other services on our website
1.General information: Cookies and similar technologies
Our website may use so-called ‘cookies’ and similar recognition technologies. Cookies are small text files that are assigned to and stored on your hard drive by the browser you are using via a characteristic string of characters and through which certain information flows to the entity that sets the cookie. Cookies cannot execute programmes or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offering more user-friendly and effective overall, i.e. more pleasant for you.
Cookies may contain data that enables the device used to be recognised. In some cases, however, cookies only contain information about certain settings that cannot be linked to a specific person. Cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. In terms of their function, cookies are divided into:
Necessary or essential cookies (technical cookies): These are essential for navigating the website, using basic functions and ensuring the security of the website; they do not collect information about you for marketing purposes or store which websites you have visited.
Functional cookies: Cookies that collect user data to provide convenient website functions, e.g. for displaying a video.
Analytical cookies (performance cookies): These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and find out what interests our users;
Marketing cookies (advertising cookies, targeting cookies): These are used to offer website users needs-based advertising on the website or offers from third parties and to measure the effectiveness of these offers; Advertising and targeting cookies are stored for a maximum of 13 months;
If consent to the storage of cookies and similar technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 (1) (a) GDPR and Section 25 (1) TDDDG); consent can be revoked at any time. If no consent is requested or another legal basis is specified, processing is based on our legitimate interest in storing cookies for the technically error-free and optimised provision of our services.
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. If you deactivate cookies, the functionality of this website may be limited.
If cookies from third-party companies or for analysis purposes are used, we will inform you separately in this privacy policy and, if necessary, request your consent.
2.Cookies, plugins and other services
Google Fonts
This site uses Google Fonts, which are provided by Google, to ensure consistent font display. When you visit a page, your browser loads the required fonts into your browser cache to display text and fonts correctly.
For this purpose, the browser you are using must connect to Google's servers. This gives Google knowledge that this website has been accessed via your IP address. The use of Google Fonts is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user's terminal device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.
If your browser does not support Google Fonts, a standard font from your computer will be used.
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.
The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the US that aims to ensure compliance with European data protection standards when processing data in the US. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
Framer
We use the Framer service, offered by Framer B.V., Stationsplein 61, 1012 AB Amsterdam, Netherlands, to operate and provide our website.
When you visit our website, Framer automatically processes certain data that is necessary for establishing a connection with the servers and securely delivering the content.
Framer may also use cookies or similar technologies that are necessary for the operation of the website (e.g. for stability or security). In addition, as website operators, we may integrate additional services (e.g. analytics or marketing tools) via Framer. These are listed separately in this privacy policy.
This data is processed in order to enable the technically error-free, secure and efficient provision of our website (Art. 6(1)(f) GDPR – legitimate interest).
Framer uses content delivery networks (CDNs) and sub-processors for certain functions, which may also be located outside the European Union (e.g. in the USA). If data is transferred to a third country, this is done on the basis of the standard contractual clauses (SCC) approved by the EU Commission in accordance with Art. 46 GDPR.
Further information on data processing by Framer can be found in Framer's privacy policy: https://www.framer.com/legal/cookie-policy/
Order processing
We have concluded an order processing agreement (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.