Version: September 2026

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection provisions is:

Vivalex Media GmbH
Schulzendorfer Str. 96
12526 Berlin
Germany

Telephone: +49 30 89391979
E-mail: info@germany24.ru

2. General information on the processing of personal data

We process personal data of users of our websites only to the extent necessary to provide our websites and their functions, to take pre-contractual measures and perform contracts, to communicate with users, and to comply with statutory obligations.

Personal data means any information relating to an identified or identifiable natural person. This may include, in particular, name, email address, telephone number, address, IP address, user and contact data, as well as order, payment and communication data.

Personal data is processed on the basis of the relevant provisions of the GDPR, in particular:

• Art. 6(1)(a) GDPR, where you have given us consent;
• Art. 6(1)(b) GDPR, where processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract;
• Art. 6(1)(c) GDPR, where processing is necessary for compliance with a legal obligation;
• Art. 6(1)(f) GDPR, where processing is necessary for the purposes of our legitimate interests or those of a third party and these interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

Where consent is required for a particular processing operation, the processing is carried out on the basis of that consent. Consent given may be withdrawn at any time with effect for the future. The lawfulness of processing carried out before withdrawal remains unaffected.

Personal data is stored only for as long as necessary for the respective purpose of processing. Data may also be stored where and for as long as statutory retention obligations apply or storage is necessary for the establishment, exercise or defence of legal claims. Once the respective purpose and any retention obligations cease to apply, the data is deleted unless another legal basis permits further processing.

3. Hosting and server log files

3.1 Hosting

Our websites are hosted on a virtual private server (VPS) provided by:

STRATO GmbHOtto-Ostrowski-Straße 710249 BerlinGermany

As part of the hosting, data required for the operation of our websites and the services offered through them is stored and processed on the servers. This may include website and database content, IP addresses, technical access data, user and contact data, user accounts, content and images uploaded by users, messages, as well as contract and order data.

The hosting provider is used to ensure the secure, reliable and efficient provision of our websites and online services. The legal basis is Art. 6(1)(f) GDPR. Where processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract, it is additionally based on Art. 6(1)(b) GDPR.

STRATO processes personal data in connection with the provision of hosting services as a processor. An agreement on commissioned processing pursuant to Art. 28 GDPR has been concluded with STRATO.

The processing contractually agreed with STRATO generally takes place in a Member State of the European Union or in another state party to the European Economic Area. If a transfer to a third country is necessary for the provision of the service, STRATO ensures compliance with the requirements of Art. 44 et seq. GDPR in accordance with the processing agreement.

Further information: STRATO privacy information

3.2 Server log files

When our websites are accessed, the user's browser transmits technically necessary information to the server, which may be stored in server log files.

• IP address of the accessing device;
• date and time of access;
• requested page or file;
• amount of data transferred;
• referrer URL;
• browser used and browser version;
• operating system used;
• HTTP status code.

This data is processed, in particular, for the technical provision of the website, to ensure the stability and security of the systems, to analyse errors, and to detect and prevent unauthorised access and attacks.

The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure, stable and technically fault-free operation of our websites.

Where STRATO processes its own user account information for error diagnosis as part of the provision of the server infrastructure, STRATO states that such information is deleted seven days after collection. The retention period for logs generated within the server operated by us or by software used on it depends on the respective technical configuration.

4. SSL/TLS encryption

For security reasons and to protect the transmission of confidential information, our websites use SSL or TLS encryption.

An encrypted connection can be recognised, among other things, by the fact that the address of the page accessed begins with “https://”.

Encryption protects data transmitted by you through our websites against unauthorised access by third parties during transmission. This applies in particular to data transmitted during registration, use of the user account, sending messages, and entering order and contact data.

In addition, taking into account the respective risk, we implement appropriate technical and organisational measures to protect personal data against loss, alteration, unauthorised access and other unlawful processing.

5. Cookies and consent management

5.1 Use of cookies and similar technologies

Our websites use cookies and comparable technologies. Cookies are small data records that can be stored on or read from a user's terminal device.

Some cookies and technologies are necessary for the technical operation of our websites and for the provision of functions expressly requested by the user. Where consent is legally required for the use of other cookies or comparable technologies, their use is governed by the applicable data protection provisions.

Where consent is required, the storage of information on the user's terminal device or access to information already stored there is based on Section 25(1) TDDDG. Subsequent processing of personal data is based on Art. 6(1)(a) GDPR.

Strictly necessary cookies and comparable technologies may be used without consent where the statutory requirements are met. Depending on the purpose, the related processing of personal data is based in particular on Art. 6(1)(b) or (f) GDPR.

5.2 Consent management with TermsFeed

We use TermsFeed Free Cookie Consent, version 4.2, to manage cookie and privacy settings.

When our websites are visited for the first time, a cookie banner is displayed through which users can make their choice. Optional categories can be accepted, rejected or configured individually.

The consent solution we use distinguishes the following categories for the technologies managed through it:

• Strictly Necessary: technologies required for basic website functions, for example login and session functions. This category cannot be disabled.
• Functionality: technologies that may provide additional functions and store certain user settings.
• Tracking: technologies used to analyse the use of our websites and measure reach, in particular in connection with web analytics services.
• Targeting: technologies that may be used for advertising, marketing or personalisation purposes.

Further information: TermsFeed Privacy Policy

5.3 Saving and changing your choice

The choice you make in the cookie banner is stored on your terminal device so that the website can take your decision into account during subsequent page views.

You may withdraw your consent with effect for the future or change your settings at any time. To do so, you can reopen the cookie Preferences Center available on our websites and enable or disable the desired categories.

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

5.4 Retention period for the consent decision

The user's choice is stored by the consent solution used in cookies on the terminal device. The cookies used to store the consent decision have a retention period of approximately 13 months.

Users may change or withdraw the stored settings at any time via the cookie Preferences Center. The relevant cookies can also be deleted using the browser. If stored consent cookies are deleted, the cookie settings may need to be requested again on the next visit to our website.

6. Google Consent Mode and Google Analytics

6.1 Google Consent Mode

Our websites use Google Consent Mode to communicate the privacy and cookie settings selected by the user to the Google services used.

When our websites are first accessed, the relevant consent signals are set to “denied” by default. This applies in particular to:

• analytics_storage
• ad_storage
• ad_user_data
• ad_personalization

The user's choice in the cookie banner is then communicated to Google via Consent Mode. If consent is granted for the relevant category, the associated signals are set to “granted”. If consent is not granted or is subsequently withdrawn, the corresponding signals remain or are set to “denied”.

The settings can be changed or withdrawn at any time via the cookie Preferences Center on our websites.

Google uses Consent Mode signals, in particular, to control the collection and use of data for analytics, measurement and advertising functions. In particular, ad_user_data and ad_personalization control whether the relevant consent exists for advertising-related measurement or personalisation.

6.2 Google Analytics

We use Google Analytics 4, a web analytics service provided by Google, on our websites.

Google Ireland LimitedGordon HouseBarrow StreetDublin 4Ireland

Google Analytics enables us to statistically analyse the use of our websites and improve our online offering. Information about page views, sessions, interactions with the website, technical information about the browser and terminal device used, and approximate location data may be processed.

For this purpose, Google Analytics uses, among other things, cookies and pseudonymous identifiers. Google describes the data collected through its tags in particular as device and browser data, information about activity on the website, and IP addresses at the time of collection.

For users in the European Union, Switzerland and the United Kingdom, Google states that individual IP addresses are not logged or stored in Google Analytics. The IP address is used to determine an approximate location and is then discarded. According to Google, the relevant processing initially takes place through domains or servers in the European Union, Switzerland or the United Kingdom.

Where consent is required for the use of Google Analytics, the storage of information on or access to the terminal device is based on Section 25(1) TDDDG and the related processing of personal data is based on Art. 6(1)(a) GDPR.

Consent may be withdrawn or changed at any time with effect for the future via the cookie Preferences Center on our websites.

The retention period for event data at user level in our Google Analytics configuration is set to two months. A retention period of 14 months is set for user data. In the event of renewed user activity, the retention period for the user identifier may be reset. According to Google, data retention settings do not affect standard aggregated reports.

Further information: Google Privacy Policy

Further information: Privacy and Google Analytics

6.3 Google Analytics where consent is denied

If consent is not granted, the corresponding Consent Mode signals remain set to “denied”. Google services take these signals into account during processing.

Depending on the technical implementation of Google Consent Mode, limited cookieless signals may still be transmitted to Google even where consent is denied. These may be used, in particular, for aggregated measurement and modelling. No corresponding analytics cookies are set for the rejected category.

7. Registration and user account

7.1 Registration

A user account must be created in order to use certain functions of our websites. This applies in particular to publishing and managing users' own classified advertisements and company listings, and to using the messaging function to contact service providers.

The following data is required for registration:

• email address;
• telephone number;
• password.

Registration takes place exclusively through our websites. Registration via external providers such as Google, Facebook or other social networks is not offered.

After registration, we send a confirmation message with an activation link to the email address provided. The user account is activated only after the email address has been successfully confirmed.

Passwords are not stored in plain text, but exclusively in hashed form.

The data required for registration is processed to create and manage the user account and to provide the functions associated with it. The legal basis is Art. 6(1)(b) GDPR.

Confirmation of the email address serves, in particular, to verify whether the email address provided is accessible to the registering user and to protect our platform against misuse of the registration function.

7.2 Voluntary information in the user profile

After registration, users may voluntarily add further information to their profile. This may include, in particular:

• name;
• date of birth;
• profile picture;
• preferred language;
• additional contact details;
• details of or links to social networks and communication services.

This information is not required to create or use the user account and is not automatically displayed publicly on our websites.

Voluntarily entered profile data is processed for the administration and individual configuration of the user account. Users can generally change or delete this information themselves.

7.3 Publication of contact details

Data stored in the user account does not become publicly accessible merely because it is stored in the user profile.

When a classified advertisement is published, the telephone number intended for the advertisement is displayed publicly. Other personal or contact data is published only if the user includes it in content intended for publication.

Section 8 additionally applies to company listings.

7.4 Deletion of the user account

Users can submit a request to delete their user account using the function provided for this purpose. The request is processed by us. After deletion, the user receives confirmation by email.

Once the request has been processed, the user account and personal data that are no longer required for its continued use are deleted. Publicly accessible classified advertisements and company listings associated with the relevant user account are removed from our websites in connection with the deletion of the account.

Individual data is retained only to the extent that a statutory obligation or another legal basis requires this. This applies in particular to order, payment, invoice and business transaction data that must continue to be retained under commercial or tax-law retention obligations or is required for the establishment, exercise or defence of legal claims.

Once the respective retention period has expired, this data is also deleted unless another legal basis requires continued retention.

8. Company listings and classified advertisements

8.1 Publication of users' own content

Registered users can create and manage their own company listings and classified advertisements through our websites.

Content entered by the user for publication is made publicly accessible on our websites in accordance with the respective function. As a general rule, the user decides which voluntary information to provide in fields and texts intended for publication.

Processing is carried out to provide the publication and platform functions requested by the user. Where publication takes place within the framework of a contract or a platform service requested by the user, the legal basis is Art. 6(1)(b) GDPR. Where processing is additionally necessary to provide and securely operate our platform, it is based on Art. 6(1)(f) GDPR.

8.2 Company listings

When a company listing is created, the following information in particular may be processed and, where intended for publication, displayed publicly:

• company name or business name;
• description of the company and its services;
• telephone number;
• business address;
• website;
• opening hours;
• contact person;
• languages in which services are offered;
• additional contact details provided by the user;
• links to websites and social media profiles;
• images and other content intended for publication.

Which voluntary information is published depends on the fields completed by the user.

Billing and invoicing data is stored separately and is not published as part of the company listing.

8.3 Classified advertisements

Registered users can create and publish classified advertisements. The data entered for the relevant advertisement and the telephone number intended for contact are displayed publicly.

Users may also voluntarily include other personal data or contact information in the published text. Such information becomes publicly accessible together with the advertisement if the user enters it in content intended for publication.

We therefore recommend that users include in publicly accessible texts only personal data whose publication is actually intended.

8.4 Images and photographs

Users can upload images in connection with company listings and classified advertisements.

Uploaded images are stored on the servers on which our websites are operated and are made publicly accessible in connection with the relevant published content.

Users should upload only images for which they have the necessary rights of use and publication and must ensure that they do not publish personal data of third parties without the appropriate authorisation.

There is no general function for uploading other files.

8.5 Address data and location display

A user can enter a business address in a company listing. The address entered may be displayed publicly in the listing and used to show the location on a map.

An automatic address search is available to assist with entering an address. Use of this function is optional; an address can also be entered without selecting a suggested search result.

Further information on the Google address search used for this purpose and on the display of locations using Google Maps can be found in Section 11.

8.6 Editorial content and events

News, editorial content and event listings are not published independently by users through user accounts. Publication is carried out by our editorial team.

Information about events is editorially processed and published on the basis of information supplied by the respective organiser or approved by the organiser for publication.

Where personal data is processed in this context, for example names, images or contact details of organisers, artists or contact persons, the processing is carried out in accordance with the respective purpose of publication and on the basis of the applicable data protection provisions.

8.7 Additional publication of selected classified ads

Selected classified ads from certain categories may additionally be published via channels and groups operated or managed by us on external platforms, in particular Telegram and Facebook.

For this purpose, titles and classified ad texts that have already been published and made publicly accessible on our website are retrieved automatically and linguistically processed using the OpenAI API. The meaning and substance of the classified ad are intended to remain unchanged. Direct contact details contained in the classified ad text or identified during automated processing, in particular telephone numbers, email addresses, usernames and comparable means of direct contact, are removed before publication on external platforms.

The processed post contains a link to the original classified ad on our website. Interested users are directed via this link to the full classified ad.

As users may also include personal data directly in a publicly accessible classified ad text, the text processed via the OpenAI API may contain such data. OpenAI processes data transmitted via the API as a processor in connection with the provision of the service. According to OpenAI, API inputs and outputs are not used by default to train or improve OpenAI models unless the API customer expressly agrees to such use.

The additional processing and publication serve to distribute and increase the visibility of the classified ad submitted by the user for publication. Where this processing forms part of the platform service requested by the user, it is carried out on the basis of Art. 6(1)(b) GDPR. Where it additionally serves to increase the reach and efficient distribution of our platform content, the processing is carried out on the basis of Art. 6(1)(f) GDPR.

9. Messaging function and communication

9.1 Contacting companies through the platform

Registered users can use the messaging function provided on our websites to contact companies or service providers published in our company directory.

The messaging function is available only to logged-in registered users.

When the messaging function is used, we process in particular:

• the content of the message;
• sender data required for contact;
• information about the sender's user account;
• the recipient of the message;
• the date and time of transmission;
• where technically necessary, other data related to the transmission.

The message is forwarded to the respective recipient through our systems. The email address stored in the company's user account is not disclosed to the sender.

This technical arrangement serves, in particular, to provide a secure means of communication through our platform and to protect the recipient's non-public email address against unwanted use and spam.

9.2 Legal basis

The data is processed to provide the messaging function requested by the user and to forward the message to the recipient selected by the user.

Where the messaging function is used in connection with a user account or use of our platform services, the legal basis is Art. 6(1)(b) GDPR.

Where processing is additionally necessary to ensure the security of our platform, prevent misuse and spam, or investigate technical incidents or misuse, the processing is based on Art. 6(1)(f) GDPR. Our legitimate interest lies in the secure and proper operation of the platform and in protecting users and service providers against misuse.

9.3 Forwarding to the recipient

The contact details and message content provided by the sender are forwarded to the company selected by the sender or to the relevant service provider.

The recipient is then independently responsible under data protection law for processing the data transmitted to it for the purpose of handling the enquiry and further communication with the sender.

Users should therefore transmit in messages only the personal data required for the respective enquiry.

9.4 Retention period

Messages and the related contact data are generally stored in our systems for six months after transmission and are then deleted.

Longer storage takes place only to the extent that statutory retention obligations apply, further storage is necessary for the establishment, exercise or defence of legal claims, or another legal reason requires it.

If a message becomes part of a contractual or business transaction and is subject to statutory commercial or tax retention obligations, the retention period is determined by the applicable statutory provisions.

9.5 Email notifications

Users can specify in their user account whether they wish to receive email notifications about messages received through the platform.

These notifications serve to inform users about use of the messaging function and do not constitute a subscription to a general advertising mailing or newsletter.

The relevant setting can be changed by the user in the user account.

10. Contract processing, orders, invoicing and payment processing

10.1 Orders and contract processing

If users order paid services through our websites, we process the data required to perform and process the respective contract.

This may include, in particular:

• name or company name;
• billing address;
• email address and telephone number;
• information about the product ordered or service booked;
• order number and date;
• invoice and payment data;
• payment method and payment status;
• information about the term and status of the order.

The data is processed to handle the order, provide the service ordered, issue invoices, process payment and manage the contractual relationship.

The legal basis is Art. 6(1)(b) GDPR. Where data must be processed or retained due to commercial or tax-law requirements, processing is additionally based on Art. 6(1)(c) GDPR.

10.2 Payment by bank transfer

When payment is made by bank transfer, the data required to execute the payment is processed by the credit institutions involved.

We process information transmitted in connection with receipt of the payment, in particular the name or account holder name, payment amount, payment reference, date of receipt and, where applicable, other payment information transmitted with the transfer.

The data is processed to identify and account for the payment and to perform the respective contract on the basis of Art. 6(1)(b) GDPR.

10.3 Payment via PayPal

We offer the PayPal payment service for payments through our websites.

PayPal (Europe) S.à r.l. et Cie, S.C.A.22–24 Boulevard RoyalL-2449 Luxembourg

If PayPal is selected, the data required to process the payment is transmitted to PayPal or collected and processed directly by PayPal. Depending on the payment method selected, this may include identification, contact, bank, payment and transaction data.

PayPal processes personal data in connection with payment processing under its own responsibility under data protection law. Depending on the service used, PayPal may carry out additional checks, in particular for fraud prevention and risk assessment.

We receive from PayPal the information required to process and identify the payment, in particular information about the status of the transaction.

Our processing is carried out for the performance of the contract and payment processing on the basis of Art. 6(1)(b) GDPR.

Further information: PayPal Privacy Statement

10.4 Invoicing and accounting with Lexware Office

We use Lexware Office to create and manage invoices and for accounting purposes.

Haufe Service Center GmbHMunzinger Straße 979111 FreiburgGermany

When Lexware Office is used, customer and company data, billing addresses, contact details, invoice and document data, information about services ordered, and payment and accounting information may in particular be processed.

Processing is carried out for invoicing, accounting and compliance with our commercial and tax-law obligations on the basis of Art. 6(1)(b) and (c) GDPR.

An agreement on commissioned processing pursuant to Art. 28 GDPR has been concluded with Haufe Service Center GmbH.

Further information: Data protection and data security at Lexware Office

Further information: Lexware Office Privacy Policy

10.5 Cooperation with tax advisers

Where necessary for our accounting, preparation of tax returns, annual financial statements or compliance with other tax and commercial-law obligations, we transmit the data and documents required for these purposes to the tax advisers engaged by us.

This may include, in particular, invoices, accounting records, customer and supplier data, payment information and other business data required for tax or accounting processing.

Processing and disclosure are carried out, in particular, for compliance with legal obligations pursuant to Art. 6(1)(c) GDPR and, where applicable, on the basis of Art. 6(1)(b) GDPR.

10.6 Retention of order, invoice and accounting data

Order, invoice, payment and accounting data is also retained after the end of the contractual relationship or deletion of the user account where statutory retention obligations apply.

The specific retention period depends on the type and legal classification of the respective documents and the applicable commercial and tax-law retention periods.

After expiry of the respective statutory retention period, personal data is deleted unless another legal basis requires further retention.

11. Google Maps and address search

11.1 Google Maps

We use Google Maps on our websites to display locations and addresses, in particular on pages of companies and other commercial service providers in our directory.

Google Ireland LimitedGordon HouseBarrow StreetDublin 4Ireland

When a page on which Google Maps is embedded is accessed, a connection to Google servers is established. In particular, the IP address, technical information about the browser and terminal device used, information about the page accessed and other data required to provide the map function may be transmitted to Google.

Google may process additional information when providing its services. If the user is simultaneously logged into a Google account, Google may in certain circumstances associate the information processed with that account. We have no influence over Google's further processing of the data.

The business address displayed on the map is generally provided by the relevant service provider or user as part of the company listing and published on our websites.

11.2 Automatic address search

When addresses are entered, in particular when creating or editing a company listing and when entering billing data, we provide an automatic Google address search.

When a user begins entering an address, the characters or parts of the address entered may be transmitted to Google in order to provide suitable address suggestions.

The user may select one of the suggestions. However, use of a suggested result is optional; an address can also be entered without accepting a result suggested by Google.

11.3 Legal basis

The integration of Google Maps and Google address search serves to facilitate address entry and provide a clear visual display of the locations of companies and service providers on our websites.

Where personal data is processed when these functions are used, the processing is governed by the applicable data protection provisions.

Further information: Google Privacy Policy

Further information: Google Maps Platform – Security and Compliance

12. Embedded YouTube videos

12.1 YouTube integration

Videos from the YouTube platform may be embedded in editorial articles and other content on our websites.

Google Ireland LimitedGordon HouseBarrow StreetDublin 4Ireland

The videos are integrated into our websites using the embedding function (iframe) provided by YouTube.

When a page containing an embedded YouTube video is accessed, a connection to Google or YouTube servers may be established. In particular, the IP address, technical information about the browser and terminal device used, information about the page accessed and other technical usage data may be transmitted to Google.

This may occur as soon as the relevant page is loaded, irrespective of whether the user subsequently plays the embedded video.

12.2 Use of YouTube

If a user plays an embedded video or interacts with the YouTube player, additional information about this interaction may be transmitted to Google or YouTube.

If the user is simultaneously logged into a Google or YouTube account, Google may in certain circumstances associate use of the embedded content with the relevant account.

We do not have full control over the nature and scope of Google's further processing of personal data or over the retention period for data processed by Google.

Further information: Google Privacy Policy (including YouTube)

12.3 Legal basis

The integration of YouTube videos serves to present editorial content in multimedia form and to provide additional video and information content.

Where the integration or use of YouTube results in personal data being processed or information being stored on or read from the user's terminal device, the processing is governed by the applicable data protection provisions.

13. External links and social networks

13.1 Links to external websites and services

Our websites may contain links to external websites, online services and third-party offerings.

As long as the user does not click such an external link, merely displaying an ordinary link generally does not establish a connection to the linked website.

Only after clicking an external link does the user leave our website or open the respective third-party offering. The operator of the external website may then process personal data, in particular the IP address and technical information about the browser and terminal device used.

The respective operator's own data protection provisions apply to its further processing of personal data. We have no influence over the processing of data by external websites and services after the relevant link has been opened.

13.2 Links to social networks and communication services

In particular, company listings in our directory may contain links to websites, social media profiles or communication services. These links are voluntarily added to the company listing by the respective service provider or user.

These are ordinary external links and not social media plugins that load content from the relevant social network merely when our website is accessed.

Only after such a link is clicked is the website or service of the relevant third party opened. From that point, the relevant provider may process personal data in accordance with its own privacy policy.

This may apply, for example, to links to social networks, video platforms, messaging services or other external online offerings.

13.3 Responsibility for externally linked content

The content and data protection practices of external websites and services are outside our area of responsibility. Users should therefore review the privacy information of the respective third party before providing personal data there.

14. Contact by email and telephone

You can contact us using the contact details provided on our websites, in particular by email or telephone.

When you contact us, we process the personal data you provide. This may include, in particular, your name, email address, telephone number, the content and subject of your enquiry, and any other information you voluntarily provide as part of the communication.

Processing is carried out in order to handle and respond to your enquiry and for the related communication.

If your contact relates to an existing contract or is aimed at entering into a contract, processing is based on Art. 6(1)(b) GDPR.

In other cases, processing is based on Art. 6(1)(f) GDPR. Our legitimate interest lies in properly handling enquiries addressed to us and communicating with users, customers and other interested parties.

Data processed in connection with an enquiry is deleted as soon as it is no longer required to handle the enquiry and any subsequent communication and no statutory retention obligations or other legal grounds prevent deletion.

If the communication forms part of a contractual or business transaction or is subject to statutory commercial or tax-law retention obligations, the relevant data may be stored for a longer period in accordance with the applicable statutory retention periods.

15. Retention period and deletion of personal data

As a general rule, we store personal data only for as long as necessary for the respective purpose of processing or for as long as a legal basis for continued storage exists.

If the purpose of processing ceases to apply and there are no statutory retention obligations or other legal grounds for continued storage, the relevant personal data is deleted.

Longer storage may be necessary, in particular, where statutory commercial or tax-law retention obligations apply, the data remains necessary for the performance or processing of a contract, is required for the establishment, exercise or defence of legal claims, or another legal obligation to retain the data exists.

Where personal data cannot be deleted because of statutory retention obligations, its processing is restricted to the purposes necessary to comply with those obligations.

15.1 Deletion of user accounts

If a user requests deletion of the user account, the account and personal data that are no longer required for its continued use are deleted once the request has been processed.

Publicly accessible content, in particular classified advertisements and company listings associated with the user account, is removed from our websites in connection with deletion of the account.

Data subject to statutory retention obligations or otherwise still required for legal reasons is not affected by deletion of the user account. This applies in particular to necessary order, invoice, payment and accounting data.

15.2 Specific retention periods

Where specific retention periods are stated in this Privacy Policy for particular processing operations, those periods take precedence.

This applies in particular to messages transmitted through our messaging function. As a general rule, they are stored for six months after transmission unless statutory or other legal grounds require longer storage.

The applicable statutory commercial and tax-law retention periods apply to invoices, accounting records and business documents.

15.3 Technical backups

Technical backups are created automatically on our servers for the backup and restoration of our websites and databases.

Personal data may therefore remain temporarily contained in existing backups after it has been deleted from the production systems.

Backups are used exclusively to ensure data security, recovery, availability and integrity of our IT systems. Data already deleted from the production systems and still contained in backups is not reused for the original processing purposes.

Backups are overwritten or deleted in accordance with the intended technical backup and deletion cycles unless statutory obligations or other legal grounds require longer retention.

16. Disclosure of data and recipients of personal data

16.1 General principles

As a general rule, we disclose personal data only where this is necessary to provide our services, perform a contract, comply with legal obligations, or where disclosure is based on another permissible legal basis.

Disclosure may take place, in particular, where it is necessary for the performance of a contract or to take steps prior to entering into a contract, where there is a legal obligation to disclose data, where processing by a processor engaged by us is necessary, where there is a legitimate interest in disclosure and this is not overridden by the interests or rights of the data subject, or where the data subject has consented to the disclosure.

The specific legal basis applicable is determined by the purpose and circumstances of the respective processing.

16.2 Categories of recipients

Depending on the function or service used, personal data may in particular be transmitted or made accessible to the following categories of recipients:

• hosting and IT service providers;
• providers of AI services for the automated linguistic processing of published content;
• providers of accounting and invoicing software;
• payment service providers and participating credit institutions;
• tax advisers and other bodies engaged to comply with statutory accounting and tax obligations;
• providers of analytics, map, address-search and embedded media-content services;
• companies or service providers to whom a registered user sends an enquiry through our messaging function;
• public authorities, courts or other public bodies where we are legally obliged to disclose data or another corresponding legal basis exists.

The service providers and services actually used are described in more detail in the relevant sections of this Privacy Policy where this is relevant to the respective processing.

16.3 Processors

Where external service providers process personal data exclusively on our behalf and in accordance with our instructions, we engage them as processors within the meaning of Art. 28 GDPR.

Where required by law, we conclude appropriate data processing agreements with such service providers.

As a general rule, processors may process personal data only within the scope of our documented instructions and for the agreed purposes.

16.4 No disclosure for third parties' own advertising purposes

We do not sell or rent our users' personal data to third parties.

Personal data is not disclosed to third parties for their own advertising purposes without the legal basis required for such disclosure.

17. Transfers of data to third countries

17.1 Processing outside the European Union and European Economic Area

When certain external services are used, personal data may be transferred to or processed in countries outside the European Union (EU) or the European Economic Area (EEA).

This applies in particular to services provided by international providers such as Google, PayPal and OpenAI where they process personal data outside the EU or EEA.

Personal data is transferred to a third country only in compliance with the requirements of Art. 44 et seq. GDPR.

17.2 Adequacy decisions and appropriate safeguards

Where the European Commission has adopted an adequacy decision for a third country pursuant to Art. 45 GDPR, data may be transferred on the basis of that decision.

Where no corresponding adequacy decision exists, a transfer may in particular be based on appropriate safeguards pursuant to Art. 46 GDPR. These include, in particular, the Standard Contractual Clauses (SCCs) adopted by the European Commission.

If none of the aforementioned bases applies in a particular case, a transfer may take place only where another basis permitted by the GDPR for a transfer to a third country exists.

17.3 Transfers of data to the USA

For transfers of data to the USA, the EU-U.S. Data Privacy Framework may in particular serve as the legal basis where the relevant recipient in the USA is certified under it.

Google LLC states that it is certified under the EU-U.S. Data Privacy Framework. Google also states that it uses Standard Contractual Clauses for data transfers where required and where the respective transfer is not covered by an adequacy decision.

Further information on the respective data transfers and the safeguards used can be found in the privacy information of the relevant providers.

Further information: Google Privacy Policy

18. Rights of data subjects

If we process your personal data, you have, subject to the statutory requirements, the following rights in particular:

18.1 Right of access

Under Art. 15 GDPR, you have the right to request information as to whether we process personal data concerning you.

If this is the case, you may in particular request information about the personal data processed, the purposes of processing, the categories of data processed, the recipients or categories of recipients and, where possible, the envisaged storage period.

In addition, subject to the statutory requirements, you have the right to receive a copy of the personal data undergoing processing.

18.2 Right to rectification

Under Art. 16 GDPR, you have the right to request the rectification without undue delay of inaccurate personal data.

Taking into account the purposes of the processing, you may also request that incomplete personal data be completed.

18.3 Right to erasure

Under Art. 17 GDPR, you have the right to request the erasure of your personal data where the statutory requirements are met.

The right to erasure exists, in particular, where the data is no longer necessary for the purposes for which it was collected or processed, the consent on which the processing was based has been validly withdrawn and there is no other legal ground for the processing, or the data has been unlawfully processed.

The right to erasure is not absolute. Continued storage may in particular be necessary where statutory retention obligations apply or the data is required for the establishment, exercise or defence of legal claims.

18.4 Right to restriction of processing

Under Art. 18 GDPR, you have the right, where the statutory requirements are met, to request restriction of the processing of your personal data.

This may apply, in particular, where you contest the accuracy of the data, the processing is unlawful, the data is required for the establishment, exercise or defence of legal claims, or a decision on an objection lodged by you has not yet been finally determined.

18.5 Right to data portability

Where the requirements of Art. 20 GDPR are met, you have the right to receive personal data that you have provided to us in a structured, commonly used and machine-readable format or to request its transmission to another controller where technically feasible.

This right applies in particular where the processing is based on your consent or on a contract and is carried out by automated means.

18.6 Right to object

Under Art. 21 GDPR, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where the processing is based on Art. 6(1)(e) or (f) GDPR.

In the event of a justified objection, we will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

18.7 Withdrawal of consent

Where the processing of personal data is based on your consent, you may withdraw that consent at any time with effect for the future.

Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

Consent to the use of the relevant cookies and technologies can in particular be changed or withdrawn via the cookie Preferences Center available on our websites.

18.8 Right to lodge a complaint with a supervisory authority

Under Art. 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you consider that the processing of your personal data infringes the GDPR.

The right to lodge a complaint may be exercised, in particular, with a supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement. This right exists without prejudice to any other administrative or judicial remedy.

18.9 Contact for data protection enquiries

To exercise your data protection rights and for questions regarding the processing of your personal data, you can contact us at:

Vivalex Media GmbHSchulzendorfer Str. 9612526 BerlinGermany

Email: datenschutz@germany24.ru

19. Automated decision-making and profiling

We do not use decision-making based solely on automated processing, including profiling, within the meaning of Art. 22 GDPR that produces legal effects concerning the persons affected or similarly significantly affects them.

In particular, no automated evaluation of users is carried out for decisions on entering into contracts, providing our services or granting access to essential functions of our websites.

The analytics and consent-management technologies used on our websites, in particular Google Analytics and Google Consent Mode, do not serve such automated decision-making by us.

20. Current status and amendments to this Privacy Policy

This Privacy Policy is current as of September 2026.

We reserve the right to amend this Privacy Policy where this becomes necessary due to changes to our websites, the functions and services offered, the technologies used, or changes in statutory or regulatory requirements.

The current version of the Privacy Policy is available on our websites.

We will provide appropriate information about material changes affecting the processing of users' personal data where this is required by law.