easybell GmbH highly values the protection of your personal data. As a provider of communications solutions, we are aware of the responsibility that comes with handling sensitive data.

For further information, please check our data policy in german or contact our data protection officer:

Mr. Christian Wilde
privacy@easybell.at

1. General Information on Data Protection

This Privacy Policy applies to the use of the easybell website, to the establishment and use of a telecommunications contract with us, and to the use of third-party services via the telecommunications connection we provide (e.g., for 0800, 0180, 0137 services from third-party providers). This policy also applies to any contact or supplier relationship you establish with us, as well as when you subscribe to newsletters or promotional materials.
This policy also applies whenever we expressly refer to it elsewhere. The entity responsible for data processing is:

easybell GmbH:

Company headquarters: Berlin
Local Court: Berlin Charlottenburg
HRB No.: 137060
VAT ID No.: DE249984363

Management: Steffen Hensche, Martin Huth, Joris Van Rymenant

 

Address:
Brückenstraße 5a
, 10179 Berlin
Phone: 030 - 80 95 1000
Fax: 030 - 80 95 1009
Email: support@easybell.de

The contact information for our Data Protection Officer is:
Christian Wilde, datenschutz@easybell.de 


We (the “data controller”) are committed to protecting your personal data. That is why we are providing you with this information about how we handle your data and our data protection principles.
We process personal data collected within the scope of this Privacy Policy in accordance with the applicable legal provisions on data protection and data security in the Federal Republic of Germany. For us, as a telecommunications company, this is the Telecommunications Act (TKG). For services not covered by the TKG, data protection has been governed in particular by the EU General Data Protection Regulation (GDPR) and the (new) Federal Data Protection Act (BDSG) enacted in connection therewith since May 25, 2018. The GDPR generally does not impose any additional obligations on telecommunications services (Article 95 of the GDPR).

1.1. Data Collection and Data Sources

We collect the data you provide to us when you use our websites. This also includes logging in to our “Online Customer Portal.”
In addition, we collect data in connection with establishing and managing a customer relationship with you as a customer of our telecommunications services, as well as traffic data (pursuant to TTDSG §§ 9–11, , GDPR Art. 6(1) ) when you use our telecommunications services or third-party services (e.g., 0800, 0180, 0137, etc.) via the connection we provide. In this case, we collect data for the purpose of establishing and maintaining the connection or providing the service, as well as for billing purposes.


If you use third-party services via the connection we provide, we will bill you for the applicable fees together with our services, depending on the nature of the service, and under certain circumstances (e.g., a payment failure) your name and address to the service provider you have chosen. The details depend on which service you use.
If you enter into a so-called “contact relationship” with us (inquiries or requests for services, newsletter subscription), enter into supplier contracts with us, or apply for a position with us, we will collect and process this data—to the extent necessary or appropriate under Article 6(f) of the GDPR.


In addition, we continue to collect data from publicly accessible sources (e.g., commercial registers, your websites, press articles, etc.) and obtain data from credit bureaus within the scope of what is permissible under Article 6(f) of the GDPR.
Personal data that we collect and store in this manner may include:

 

  • IP address and usage data when accessing website content;
  • Name, address, and other contact information (phone numbers, email address, fax number, etc.), registration numbers, names and addresses of authorized representatives, account information, and the corresponding contact details of the relevant representatives on your behalf as a customer of our services;
  • Additional inventory or product data, as well as traffic and billing data within a customer relationship, such as selected products and rates, billed services (calls), and payment data;
  • Itemized billing records for customer orders, with either a shortened or full display of the called party’s phone number
  • Name and contact information in connection with the establishment and management of a customer relationship or a supplier relationship.
  • Data that you enter or share when using the easybell customer portal, e.g., email addresses or contact phone numbers, phone numbers for blocking and whitelists, caller ID, and call logs, provided you have activated these features
  • Name and email address when subscribing to the newsletter, as well as mailing information for the respective newsletters.
  • Information we receive from credit reporting agencies pursuant to Article 6(1)(f) of the GDPR.


All personal data is collected only within the scope of a legal authorization or if you have given us your consent.  

1.2. Use and Disclosure of Personal Data in General

We use your personal data to enable you to use our website. In addition, your data is processed and transmitted when you use our websites, provided you consent to the use of anonymized analytics services (e.g., Google Analytics); see Section 8 for details.

We generally use your personal data to establish and fulfill a contract with you as a service provider, as well as for billing purposes.
If you use our telecommunications network via a phone call or connection, we use your data to enable this use and to bill you for it. Data may be transferred to other network operators or providers of telecommunications services if this is necessary for the service you, as the user, have selected—such as when routing calls to other destination networks or receiving calls to your line from other source networks. In addition, data is exchanged with interconnection network operators when you use services that are implemented in a so-called interconnection network (e.g., 0800, 0180, 0137 services, etc.), to the extent necessary for the provision of the respective service, its billing, and the collection of fees. In this context, it may be necessary for us to also exchange your data with the respective service provider you have selected, for example, in cases of payment issues.

If you enter into a contact, supplier, or employment application relationship with us, we use your data to establish, fulfill, or process this relationship and, if applicable—to the extent relevant—to bill for it.
In addition, we use data lawfully obtained for the purpose of advertising by mail, as well as by email or telephone, provided you have given your specific and valid consent. If, within the framework of an existing customer relationship involving telecommunications services, we have lawfully obtained your phone number or mailing address, including electronic ones, we may use this information to send text or image messages to a phone number or mailing address for the purpose of advertising our own offers, conducting market research, and informing you of a specific request for contact, unless you have objected to such use. When collecting or initially storing the phone number or address, and each time a message is sent to that phone number or address, we will clearly and legibly indicate that you may object to the sending of further messages at any time in writing or electronically.
In general, it may also be necessary for us to disclose your data to external service providers within the scope of data processing on our behalf. In addition, within the scope of the authorization under Article 6(1)(f) of the GDPR, we may exchange data with credit reporting agencies if this is necessary or appropriate for the establishment of a contract or the enforcement of claims. We will neither sell your personal data to third parties nor market it in any other way.

Data transfers to third countries occur in connection with the administration, development, and operation of IT systems and only to the extent that a) the transfer is generally permissible and b) the specific requirements for a transfer to a third country are met, in particular, the data importer ensures an adequate level of data protection in accordance with the EU Standard Contractual Clauses for the transfer of personal data to processors in third countries. This is based on the provisions of the GDPR and the Federal Data Protection Act. A transfer may also occur when using our websites; see Section 8 for details.

1.3. Options for Telecommunications Services

Itemized Bill

During the ordering process, you can choose whether you want a full itemized bill, an abbreviated itemized bill, or to opt out of receiving an itemized bill altogether. You can then download your itemized bills monthly from the easybell customer portal.  
You can choose to have the destination phone numbers stored with the last three digits omitted; otherwise, easybell will store the full destination phone number. If you dispute the amount of an invoice, the abbreviated storage of the destination phone number means that easybell is exempt from the obligation to provide traffic data to verify the accuracy of the invoice.
Residential customers must confirm in writing that they have informed co-users of the telecommunications service regarding the itemized billing. For connections at businesses and government agencies, (pursuant to Section 99(1), Sentence 4 of the German Telecommunications Act (TKG)), written confirmation is required stating that employees have been informed, that future employees will be informed without delay, and that the works council or employee representative body has been consulted in accordance with statutory provisions or that such consultation is not required.

Call Lists

You can activate or deactivate a call log at any time in the easybell customer portal. By activating it, you agree to inform all co-users.
Call logs include incoming, outgoing, and missed calls and contain the phone numbers of the caller and the recipient, the time, the duration of the call, and the name of the SIP client through which the call was made.
You can delete the list at any time. However, it will be automatically deleted after six months at the latest.

Caller ID

If you have ordered a phone line from easybell, your line will be set up so that the caller’s phone number is displayed to the recipient. If you do not wish this, you can configure the easybell customer portal to determine whether your phone number is displayed to the recipient or not.
Even if caller ID is suppressed, the phone number can still be retrieved using appropriate devices (e.g., call capture systems).
With the Caller ID feature (also known as “User Provided Number,” or UPN), you can specify a phone number in the easybell customer portal for which you have the right to use, and this number will be transmitted in addition to the number assigned by easybell. This additional number is typically displayed to the recipient. Your original phone number is visible at all times to the police, emergency services, call centers, law enforcement agencies, and customers with compatible devices.

Subscriber Directories:

If you request it, easybell will ensure that the data specified in consultation with the customer (name, address, and, if applicable, additional information such as occupation, industry, and type of connection) is listed in printed and/or electronic directories as well as in telephone directory assistance services. If you have consented to such publication, easybell is obligated to disclose this data upon request to companies that publish public subscriber directories and/or offer telephone directory assistance services. You have the right to object to the listing at any time or to restrict the scope or nature of the publication. If you authorize the use of the data published about you in a subscriber directory for so-called reverse lookups, your name and address will be disclosed by directory assistance providers to any third party who simply provides your phone number. You may revoke this authorization at a later date.

Blocking Unwanted Calls

In the easybell customer portal, you can block the forwarding of unwanted calls, such as anonymous calls or harassing sales calls (“blocklist”). Alternatively, you can also explicitly specify phone numbers that you are the only one allowed to call.

2. Purposes of Data Processing

We process the aforementioned personal data in accordance with the provisions of the GDPR and the Federal Data Protection Act (BDSG), as well as—where applicable—the Telecommunications Act (TKG):

2.1. To fulfill contractual or precontractual obligations (Art. 6(1)(b) of the GDPR)

Personal data is processed in connection with your use of our website, to fulfill a contract with you as a customer, when you use our network, and in the context of a contact or application relationship. The purposes of data processing and the necessity thereof are primarily determined by the specific purpose defined by the aforementioned legal relationships.

In the context of a contract with you as a customer, this includes, in particular, the establishment, structuring, performance, consultation, and billing of such a contract, along with the services you use, as well as the exchange of personal data with business partners who must be involved (e.g., the outgoing or incoming network operators when switching providers, data exchange with interconnection partners). When you use our network, we also exchange data with other network operators to the extent necessary to establish and maintain the connection or to provide the requested service, as well as for billing and invoicing, including debt collection. This also includes storing data regarding your payment history. We require this data to carry out collection procedures or to implement a potential service suspension.

Data is also processed to handle your inquiries and to initiate customer relationships or similar contact arrangements, as well as in connection with job applications.

For the aforementioned purposes, it may also be necessary for us to transfer your data to group companies or external service providers, in each case within the scope of data processing on behalf of the controller.

2.2. Processing Based on a Balancing of Interests (Art. 6(1)(f) of the GDPR)

To the extent necessary for our purposes, we process your data beyond the actual fulfillment of the preliminary agreement or contract to protect our legitimate interests or those of third parties, unless your interests in refraining from such data processing outweigh ours:

  • Anonymization of IP addresses when using our website for statistical purposes, data security, and the optimization of our website.
  • Use of our website with social media plug-ins that involve data exchange with social media platforms, provided the user does not object to this data transfer by blocking JavaScript or loading a plug-in that prevents the transfer. In this case, the use of the website’s functionality may be restricted; see Section 8 for details. The processing is based on Section 15(3) and Section 13(1), sentence TMG, as interpreted in accordance with the e-Privacy Directive 2002/58, Article 5(3), and in conjunction with Article 95 of the GDPR; as a precautionary measure, also on Article 6(1)(f) of the GDPR.
  • Possible data security measures on our website, such as, in particular, the storage of IP addresses, provided that the specific threat situation makes this appear appropriate.
  • Establishment and fulfillment of contractual relationships within the scope of necessity
  • Collection of outstanding receivables; for this, we work with reliable partners; see Section 7.
  • Direct mail, unless you object to it.

2.3. Processing Based on Your Consent (Art. 6(1)(a) of the GDPR)

If you give us your consent to process personal data for a specific purpose in accordance with the applicable guidelines, we will process that data within the scope of your consent.

2.4. Processing Based on Legal Requirements (Art. 6(1)(c) of the GDPR and Sections 170–172 of the TKG)

We process your personal data to the extent that we are subject to a legal obligation, such as statutory retention requirements or obligations to provide information or comply with monitoring requirements imposed by government agencies in accordance with the law.

3. Transfer of Data to Third Parties

Within our company, access to your data is granted to those individuals who are entrusted with processing it to the extent that it is necessary or reasonably appropriate. Service providers and agents engaged by us may also be granted access to personal data for these purposes, provided they comply with our written data protection instructions, maintain general data confidentiality within the scope of data processing on our behalf, and—where applicable—maintain telecommunications confidentiality.

To obtain business and credit information, we work with credit reporting agencies (third parties); see Section 6. For debt collection, we work with third parties; see Section 7.
Customers can use the customer portal at any time to decide for themselves whether data should be shared with printed telephone directories, electronic directories, and telephone information services. They can also decide whether, in addition to their last name, their first name and address should be published, and whether a reverse lookup is permitted.


In particular, we will not transfer any personal data to third parties for advertising or address trading purposes.


When using our website, data is transmitted to Google and social media providers; see Section 8.

3.1. Sharing with Infrastructure Partners and Technical Teams

To enable the installation and operation of telecommunications connections, we share the necessary personal data with our infrastructure partners in accordance with legal requirements. If necessary, these partners will assign technicians to install or troubleshoot your subscriber line (TAL).

3.2. Disclosure to Network Operators and Service Providers

As part of the provision of services on our network, data is exchanged with participating network operators and other service providers in accordance with the Telecommunications Act (TKG). This occurs, in particular, when switching providers, when establishing and maintaining connections across network boundaries, and for billing and the collection of receivables. This transmission takes place only to the extent necessary, as prescribed in Sections 59 et seq. of the TKG. The specifics of the data exchange and data processing depend on the type of service used. If you use third-party services via the connection we provide, you will receive further details from those third parties. Since we are not aware in advance of the possible third-party providers you use via our connection, we cannot provide you with specific information here regarding the address at which you can reach your respective third-party service provider.

3.3. Transfer to Logistics Companies

In order to ship a hardware order (Art. 6(1), sentence 1, letter b of the GDPR) and based on our legitimate interests in making shipping as straightforward as possible for you (Art. 6(1), sentence 1, letter f of the GDPR), we transmit the necessary data (name, company name, shipping address, and, if applicable, email address) to the contracted shipping service provider. This is used exclusively for the delivery of goods and to notify you of the delivery. Shipping service providers are subject to postal secrecy.

Partner Stored Data Retention Period
DHL / Deutsche Post Title, first and last name, company name (if applicable), shipping address, email address Up to 6 months after contract fulfillment

3.4. Transmission for the Purpose of Address Verification

To verify your address, you can complete an automated online identity verification process through our partner, Nect GmbH, Großer Burstah 21, 20457 Hamburg. For this process, a case ID is created at Nect GmbH. Initially, no personal data is associated with this case ID. During the identification process, Nect GmbH will verify your ID card, electronic residence permit, or passport and compare the photo on the document with a photo taken on the spot. Subsequently, the result of the identity verification, your first and last name, your date of birth, and your registered address—linked to the Case ID—are transmitted to easybell GmbH. This data is then compared with the information we have on file for you.

3.5. Transmission for the Purpose of Preparing or Submitting a Bid

When you use our ordering processes to create or submit a quote, the data you provide is transmitted to our web-based CRM system operated by weclapp GmbH (Neue Mainzer Straße 66–68, 60311 Frankfurt am Main) based on your consent and our legitimate interest pursuant to Art. 6(1)(f) GDPR. weclapp stores and processes this data on our behalf exclusively on servers located in Germany. You can find weclapp’s privacy policy at Privacy Policy. The transmitted data is automatically deleted after 30 days.

4. Data Transfer to a Third Country or to International Organizations

Data will only be transferred to countries outside the EU or the EEA (“third countries”) to the extent necessary to fulfill the contractual relationship (contract with the service provider or for the use of the services provided on our network). In the case of other contractual relationships, such as a contact relationship or a job application, such data transfers will only take place to fulfill that contractual relationship or, in exceptional cases, to the extent that this is appropriate based on a legitimate interest. The same applies to the use of our website from locations outside the EU or the EEA. When using our website, data is transferred to Google and social media providers; see Section 7.

5. Data Retention Period

In general, data is stored in accordance with Article 6(1) of the GDPR, Sections 9–12 of the TTDSG, Section 172 of the TKG, Section 257 of the HGB, and Section 147 of the AO. When you use the website, we store your IP address and usage data for the duration of your session. In addition, the IP address is stored to the extent that this is appropriate for data security and for investigating or preventing security or data protection breaches, with the appropriateness determined by the specific threat situation. In this case, IP addresses are stored only for as long as is appropriate for the aforementioned purposes, generally not exceeding three months. In the event of a criminal complaint, criminal prosecution, or the enforcement of claims against individuals who commit security or data protection breaches, the data may be stored and used until the claims have been fully resolved or enforced. When you use our website, data is also transmitted to analytics services; see Section 8.


To establish, structure, and fulfill a contract with you as a customer of telecommunications services, we store the data until the end of the contract and beyond, specifically until the end of the calendar year following the year in which the contract terminates. Upon expiration of this period, the data is not deleted but rather blocked, as we are required by commercial and tax law to store the data for up to 10 years. This storage requirement also applies to invoice amounts. Specifically regarding individual calls and the resulting billing data, we store this information for a period of 3 calendar months, provided this is necessary for billing purposes with you or other network operators or service providers. If you, as the party liable for payment, raise objections within the prescribed time limit, the data will be stored until the objections are resolved or the debt is collected. Upon deletion, easybell GmbH is released from the obligation to submit traffic data as proof of the invoice’s accuracy. Further storage occurs only in exceptional cases, when permitted under Article 6(1)(f) of the GDPR and/or Section 12 of the TTDSG (e.g., troubleshooting, investigating and preventing misuse).


If the call log feature is enabled, the customer can delete it themselves at any time. Automatic deletion occurs no later than six months after the call. This also applies to requested itemized billing records.
easybell does not store dynamically assigned IP addresses in its own systems. Our suppliers have assured us that the stored IP addresses are deleted no later than 7 days after the end of the connection. This also applies to incoming calls, unless the customer explicitly requests that they be stored as part of call logs.


In the context of a customer relationship, contact information and communication data are stored and used to the extent necessary for the respective communication purpose or to the extent that it is appropriate and necessary for that purpose.


In the context of a job application, contact information and application data are stored and used to the extent necessary for the respective purpose of the application or to the extent that such use is appropriate and necessary for that purpose. If the application is not successful, the data will be deleted within two months of notification of the rejection, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, the burden of proof in proceedings under the General Equal Treatment Act (AGG).
If you subscribe to our newsletter or enter a contest, your data will be stored and used until you unsubscribe from the newsletter or we discontinue the newsletter. Your consent and the information regarding previous mailings will remain stored until the statute of limitations expires for any potential claims for injunctive relief on your part; however, we will no longer use the data to send you further newsletters. The details regarding data processing are set forth in the respective contest rules.

6. Data Transfer to Credit Bureaus

We transmit personal data collected within the scope of this contractual relationship (name, address, and, if applicable, date of birth) for the purposes of applying for, carrying out, and terminating this business relationship, as well as data regarding non-contractual or fraudulent behavior, to Creditreform Boniversum GmbH, Hammfelddamm 13, 41460 Neuss.


The legal basis for these transfers is Article 6(1)(b) and Article 6(1)(f) of the GDPR. Transfers based on Article 6(1)(f) of the GDPR may only take place to the extent that this is necessary to safeguard our legitimate interests or the legitimate interests of third parties and does not override the interests or fundamental rights and freedoms of the data subject that require the protection of personal data. The exchange of data with Creditreform Boniversum GmbH also serves to fulfill legal obligations to conduct creditworthiness checks on customers (Sections 505a and 506 of the German Civil Code (BGB)).


Creditreform Boniversum GmbH processes the data it receives and also uses it for profiling (scoring) purposes in order to provide its contractual partners in the European Economic Area and Switzerland, as well as, where applicable, other third countries (provided that an adequacy decision by the European Commission exists for these countries) information, among other things, for the purpose of assessing the creditworthiness of natural persons. Further information on the activities of Creditreform Boniversum GmbH can be found online at www.boniversum.de.

7. Collection of Outstanding Debts

To the extent that the collection of an outstanding debt becomes necessary under the contractual relationship or otherwise in the course of protecting our legitimate interests—and provided that this does not override the interests of the data subject’s fundamental rights and freedoms that require the protection of personal data — we will alternatively commission the following legal entity to collect the debt:


coeo Inkasso GmbH
Kieler Straße 16
41540 Dormagen


The data necessary for collection will be transmitted to the respective legal entity commissioned. The legal bases are Article 6(1)(b) and Article 6(1)(f) of the GDPR, as well as Section 95(5) of the German Telecommunications Act (TKG). For further information regarding data processing by the aforementioned legal entities, please contact them at the addresses provided.

8. Specific Processing in Connection with Website Use

8.1. Information Collected Automatically for Web Analytics

For technical reasons, your web browser automatically transmits data to the web server when you access the site. In addition to providing the service, this data is collected for marketing and optimization purposes.

8.2. Data Analysis and Cookies

easybell uses so-called “cookies.” These are small text files that are stored on your computer and contain information used for identification purposes. They are set when you log in to authenticate the user during their active session. You can delete these cookies from your computer at any time. The easybell.de website can only be used to a limited extent without cookies.

You can also completely prevent cookies from being stored by adjusting the settings in your browser. However, please note that in this case, you may not be able to use all of the website’s features.

8.3. Service Cookies and Necessary Cookies

Most of the cookies we use are so-called service cookies, which we set when you visit our website in order to securely provide the service you have requested. These cookies are technically necessary.

Name Purpose Retention Period  
CookieConsent Stores your consent to the use of cookies 1 year  
XSRF-TOKEN Prevents cross-site attacks in the customer portal End of session (leaving the page, closing the browser)  
EKP_Session Enables login to the customer portal End of session (leaving the page, closing the browser)  
Piwik: _pk_id Usage statistics in the customer portal 13 months  
Piwik: _pk_testcookie Usage statistics in the customer portal End of session (leaving the page, closing the browser)  
_pk_id Used to assign a unique visitor ID to the user. 13 months  
_pk_ses Cookie used to incorporate details of your visit into usage statistics. 30 minutes  
fe_typo_user Assigns your browser to a session on the server. This only affects the content you see and is not analyzed or further processed by us. End of session (leaving the page, closing the browser)
apcCheckData Stores the result of the DSL availability check 24 hours  
order_session Stores the result of the DSL availability check 36 hours  

8.4. Measurement and Analysis Services

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies,” which are text files stored on your computer that enable an analysis of your use of the website. The information generated by the cookie regarding your use of this website is typically transmitted to a Google server in the United States and stored there. However, if IP anonymization is enabled on this website, Google will first truncate your IP address within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google.

The following cookies are stored upon consent when using Google Analytics:

Name Purpose Retention Period
_ga Website statistics: Identification of returning visitors (anonymized) 2 years
_ga_V3PFWQFH0B Used to maintain session status. 2 years

Objection to Data Collection

In addition to disabling cookies in general, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. This will place an opt-out cookie on your device.

You can prevent data collection by Google Analytics by clicking the following link to disable Google Analytics for this browser. An opt-out cookie will be set to prevent the future collection of your data when you visit this website.

Please note, however, that in this case you may not be able to use all of this website’s features to their full extent. If you delete your cookies, you will need to click the link again.

For more information on our Terms of Use and Privacy Policy, please visit www.google.com/analytics/terms/de.html or www.google.de/intl/de/policies/. Please note that Google Analytics on this website has been extended with the code “gat._anonymizeIp();” to ensure that IP addresses are collected anonymously (so-called IP masking).

Google Signals

We have enabled the Google Signals feature in Google Analytics. If you have authorized personalized ads in your Google Account, this feature updates Google Analytics to collect aggregated and anonymized data from you. Data is collected via cross-device tracking. This allows your data to be analyzed across devices. When you enable Google Signals, data is collected and linked to your Google Account. 

Google Signals also collects additional user data in Google Analytics. In addition to your interests, this includes demographic characteristics such as your age, location, city of residence, language, and gender. Social characteristics such as your occupation, marital status, or income may also be collected. By collecting these characteristics, Google Analytics can define user groups or target audiences.

The purpose of data collection and processing via Google Analytics and Google Signals is to better understand your behavior, preferences, and interests. This allows services and products to be tailored and optimized for you. 

The data collected in this manner is stored for 26 months. In your Google Account, you can manage this data, customize its use, and delete it.

Google Tag Manager

We implement Google Analytics (Universal) using “Google Tag Manager.” Google Tag Manager is also a Google product that allows us to manage website tags through a single interface. Google Tag Manager is a cookie-free domain and does not collect any personal data. The tool triggers other tags, which may in turn collect data. Google Tag Manager does not access this data. If deactivation has been performed at the domain or cookie level, it remains in effect for all tracking tags implemented with Google Tag Manager.

Matomo

This website uses Matomo, a self-hosted open-source software, to collect anonymous usage data for this website.

Data on visitor behavior is collected to identify potential issues such as pages not found, search engine problems, or unpopular pages. Once the data (number of visitors, error pages, single-page views, etc.) is processed, Matomo generates reports for website operators so they can take appropriate action (layout changes, new content, etc.).

Matomo processes the following data:

  • Cookies
  • Anonymized IP addresses, with the last 2 bytes removed (e.g., 198.51.0.0 instead of 198.51.100.54)
  • Pseudo-anonymized location (based on the anonymized IP address)
  • Date and time
  • Title of the page visited
  • URL of the page accessed
  • URL of the previous page (if permitted)
  • Screen resolution
  • Local time
  • Files that were clicked on and downloaded
  • External links
  • Page load time
  • Country, region, city (with low accuracy based on IP address)
  • Browser's primary language
  • Browser user agent
  • Interactions with forms (but not their content)
  • The customer number of the logged-in user in the customer portal

When you use this website, your visit is logged by the website’s host. This log contains your IP address, which indirectly identifies you through your internet service provider. Logging this data is required by law and necessary for security purposes. There is no option to opt out, but the data will never be used for any other purpose.

Data processing is based on the principle of legitimate interest.

Processing this data helps us determine what works on our site and what does not. For example, it allows us to determine whether the content is well-received or how we can improve the website’s structure. Our team benefits from this and can act accordingly. As a result of this data processing, you benefit from a website that is constantly improving.

Without this data, we would not be able to provide this service. Your data is used exclusively to improve the user experience on our website.

Matomo data is hosted in Germany. The data never leaves the EU.

Since Matomo collects data based on legitimate interests, you can exercise the following rights:

  • Right of access and data portability: You may request all of your data at any time.
  • Right to erasure and rectification: You may request at any time that we completely erase all your data.
  • Right to object and restrict processing: You may object to data collection at any time by enabling “Do Not Track” in your browser or opting out of Matomo tracking.

Microsoft Clarity

We work with Microsoft Clarity and Microsoft Advertising to track how you use and interact with our website—using behavioral metrics, heat maps, and session replays—to improve and market our products and services. Website usage data is collected using first-party and third-party cookies and other tracking technologies to determine the popularity of products/services and online activities. We also use this information to optimize the website, for fraud and security purposes, and for advertising. For more information about how Microsoft collects and uses your data, please see the Microsoft Privacy Statement.

Cookies used for Microsoft Clarity:

Name Purpose Validity
_clck Consists of the Clarity User ID and the preferences uniquely associated with that User ID for this page. 1 year
_clsk Links multiple page views by a user to a single Clarity session recording. 1 day
CLID Identifies the user who first encountered Clarity on any site. 1 year
ANONCHK Indicates whether the MUID is transferred to ANID, an advertising cookie. Clarity does not use ANID, so this value is always set to 0. 10 minutes
MR Indicates whether the MUID should be updated. 7 days
MUID Identifies unique web browsers visiting Microsoft sites. These cookies are used for advertising, website analytics, and other operational purposes. 1 year
SM Used to synchronize the MUID across Microsoft domains. Session duration

Use of HubSpot

We use HubSpot, a service provided by HubSpot Inc. (U.S.) and HubSpot Germany GmbH, Am Postbahnhof 17, 10243 Berlin, to analyze website visits, for marketing automation, and for customer relationship management (CRM).

Purpose of processing:
Processing is carried out to analyze user behavior on our website, optimize our marketing activities, and improve customer communication. In doing so, personal data such as IP addresses, pages visited, timestamps, form content, and interactions with our website may be collected and stored.

In addition, in connection with requests for quotes and orders, we store other personal data such as company name, contact person, email address, phone number, and mailing address. As part of communication with our sales team, the content of conversations may also be documented in writing to ensure consistent and targeted customer service.

Legal basis:
Processing is based on your consent pursuant to Art. 6(1)(a) of the GDPR, which you can provide via our cookie banner. The use of the CRM system may also be based on Art. 6(1)(b) (performance of a contract).

Cookies and Tracking:
HubSpot uses cookies to collect information about user behavior. These cookies are only set if you provide your consent via our cookie banner. For more information about the cookies we use, please see our Cookie Policy.

Retention Period:
Personal data collected via HubSpot is generally automatically deleted after 30 days, provided there is no further interaction. Data is retained for a longer period only:

  • in the case of an order, for the purpose of fulfilling the contract and providing customer service,
  • or in the case of double-opt-in consent, e.g., to receive newsletters or other marketing information.

Data Transfer to Third Countries:
Data processing takes place exclusively in EU data centers.

Your rights:
You have the right to access, rectify, erase, restrict the processing of, and data portability, as well as the right to object to the processing of your personal data. You may revoke your consent at any time with future effect.

For more information on data processing by HubSpot, see: HubSpot Privacy Policy 

Cookies used by HubSpot:

Name Purpose Expiration
__hstc HubSpot’s main tracking cookie, which contains the domain, user token, first timestamp, last visit timestamp, current visit timestamp, and session number 6 months
hubspotutk Tracks a visitor’s identity. Used to transmit the visitor’s identity to HubSpot when forms are submitted 6 months
__hssc Tracks sessions. Used to determine whether HubSpot should increment the session ID and timestamps 30 minutes
__hssrc Determines whether the visitor has started a new session. Set when the session cookie changes Session duration
__hs_opt_out Stores the visitor’s opt-out preference for HubSpot tracking 6 months

8.5. YouTube

Our website uses the YouTube button from the social network YouTube, which is operated by YouTube LLC, headquartered at 901 Cherry Avenue, San Bruno, CA 94066, USA (“YouTube”). When you visit a page on our website that contains such a button, your browser establishes a direct connection to YouTube’s servers. The content of the YouTube button is transmitted directly from YouTube to your browser and integrated into the webpage by your browser. We therefore have no influence over the scope of the data that YouTube collects via the button, but we assume that your IP address is also recorded. For information on the purpose and scope of data collection, as well as the further processing and use of the data by YouTube, and your rights and privacy settings in this regard, please refer to YouTube’s privacy policy regarding the YouTube button:


https://support.google.com/youtube/answer/2801895?hl=de


If you are a YouTube member and do not want YouTube to collect data about you via our website and link it to your member data stored on YouTube, you must log out of YouTube before visiting our website.

8.6. Google Ads and Remarketing

easybell uses Google Ads and Google Remarketing. These are advertising services provided by Google Inc. (“Google,” Mountain View, USA). These features are used to display interest-based ads to website visitors within the Google Display Network. To do this, the browser stores cookies that make it possible to recognize the user or the browser when they visit websites that are part of Google’s advertising network.

On these sites, visitors may then be shown ads related to content they previously viewed on websites that use Google’s remarketing feature. According to Google, no personal data is collected during this process. However, if you do not wish to use Google’s remarketing feature, you can generally disable it by adjusting the relevant settings in Google Ads Manager.

Alternatively, you can prevent remarketing by disabling cookies in your browser settings.

For more details, see the Google Ads Privacy Policy.

Cookies used for Google Ads:

Name Purpose Validity
_guid Used to identify a LinkedIn member for advertising via Google Ads. 90 days
_gcl_au Used to measure ad and campaign performance as well as conversion rates for Google Ads on a visited website. 90 days
_gcl_aw Used via Google Ads to understand user interaction with the website and advertisements. 90 days
_gcl_dc Used via Google Campaign Manager and DV 360 to understand user interaction with the website and advertisements. 90 days

8.7. Social Media

 

Our website uses social plugins. When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to the respective server. As a result, the social media provider receives the information that you have visited the corresponding page on our website and can associate this information with your account, provided you are logged in. If you do not want the social media provider to collect data about you through our website, you must log out of your social media account before visiting our website or decline to accept the relevant cookies on our site.

Facebook / Instagram

Company: Meta Platforms Inc.
Facebook: The entity responsible for the European region is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
. Instagram: Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA
. Purpose: When you visit our pages, a direct connection is established between your browser and the Facebook server via remarketing tags. Facebook thereby receives the information that you have visited our site using your IP address. This allows Facebook to associate your visit to our pages with your user account. We may use the information obtained in this way to display Facebook Ads. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how Facebook uses it.
Legal basis: Consent
Privacy Policy:

Opt-out link: www.facebook.com/ads/website_custom_audiences

Related cookies:

 

Name Purpose Expiration Date
_fbp Used by Facebook to deliver a range of advertising products, such as real-time bids from third parties 3 months
fr Targeting cookie for Facebook ads 3 months

LinkedIn

Company: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA
Purpose: When you visit our pages, the plugin establishes a direct connection between your browser and the LinkedIn server. The LinkedIn Insight Tag enables us to evaluate our LinkedIn ads and collect information about website visitors who have reached us through our ads on LinkedIn.
Legal basis: Consent
Privacy Policy: https://www.linkedin.com/legal/privacy-policy

Related cookies:

 

 

Name Purpose Expiration  
AnalyticsSyncHistory This cookie is set by LinkedIn. It is used to store information about when a synchronization with the lms_analytics cookie took place for users in designated countries. 30 days  
UserMatchHistory Synchronization of the LinkedIn Ads ID 30 days  
bcookie Browser identifier cookie used to uniquely identify devices accessing LinkedIn in order to detect abuse on the platform. For more information about LinkedIn cookies, visit https://www.linkedin.com/legal/l/cookie-table. 1 year  
bscookie Used to store a user’s language preference so that LinkedIn.com is displayed in the language the user has selected in their settings. 1 year  
lang This domain belongs to the business networking platform LinkedIn. It typically acts as a third-party host where website owners have placed one of its content-sharing buttons on their pages, although its content and services can also be embedded in other ways. Although such buttons enhance the functionality of the website on which they appear, cookies are set regardless of whether the visitor has an active LinkedIn profile or has agreed to the terms of service. For this reason, it is classified as a domain primarily used for tracking/targeting. For more information about LinkedIn cookies, visit https://www.linkedin.com/legal/l/cookie-table. During the session  
li_sugr Used to perform a probable match of a user’s identity outside the designated countries 90 days  
lidc Required for selecting a data center. 24 hours  

8.8. Integration of Review Platforms

This page incorporates so-called widgets from review platforms to inform customers about other customers’ experiences with easybell. A widget is a functional and content element integrated into our website that displays dynamic information. Although the corresponding content is displayed on our website, it is retrieved in real time from the review platform’s servers. This is the only way to ensure that the most up-to-date content—especially the current rating—is always displayed.

Trustami

The Trustami trust seal is integrated into this website to display collected reviews and social media feedback. This serves to implement our legitimate interests in optimally marketing our offerings on our own website in accordance with Art. 6(1)(f) of the GDPR. When the Trustami trust seal is accessed, the web server automatically stores data (access data) in the form of a server log file, which includes the name of the accessed webpage, the file, the date and time of the access, your IP address in truncated form, the amount of data transferred, a notification of a successful access, the browser type, the user’s operating system, the referrer URL (the previously visited page), and the requesting provider. This access data is not analyzed and is automatically overwritten no later than seven days after the end of your visit to the site. The Trustami Trust Seal and the services advertised through it are provided by Trustami GmbH, Schröderstraße 5, 10115 Berlin. The processing of data collected by Trustami is governed by Trustami’s privacy policy available at

www.trustami.com/datenschutz.

 

Trustpilot Reviews

We participate in the review program offered by Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark.

Trustpilot offers users the opportunity to rate our services. Users who have used our services are asked to consent to receiving a review request. If users have given their consent (for example, by clicking a checkbox or a link), they will receive a review request with a link to a review page. To ensure that users have actually used our services, we transmit the necessary data regarding the user and the service used to Trustpilot (this includes the name, email address, and a reference number). This data is used solely to verify the user’s authenticity and to contact them.

The legal basis for processing the user’s data as part of the review process is consent pursuant to Art. 6(1)(a) of the GDPR.

To submit a review, you must create a customer account with Trustpilot. In this case, Trustpilot’s Terms of Service and Privacy Policy apply. To ensure the neutrality and objectivity of the reviews, we have no direct influence over the reviews and cannot delete them ourselves. We ask users to contact Trustpilot for this purpose.

Furthermore, we may integrate the Trustpilot widget into our website. To do so, a data connection must be established from the webpage accessed within our online service to Trustpilot, and Trustpilot receives certain technical data (access data, including the IP address) necessary for the content to be delivered. Furthermore, Trustpilot receives information indicating that users have visited our online service. This information may be stored in a cookie and used by Trustpilot to identify which online services participating in the Trustpilot review process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

The legal basis for processing the user’s data in connection with the integration of the widget is our legitimate interest in informing our users about the quality of our services pursuant to Art. 6(1)(f) of the GDPR. If we ask users for consent to the processing of their data through the use of cookies, the legal basis for the processing is Article 6(1)(a) of the GDPR.

Users can find further information regarding the processing of their data by Trustpilot, as well as their rights to object and other data subject rights, in Trustpilot’s Privacy Policy:

https://de.legal.trustpilot.com/end-user-privacy-terms

8.9. Surveys with SurveyMonkey

To improve our services and products, we gather customer satisfaction feedback, including on our website, using the SurveyMonkey survey tool provided by Momentive Europe UC (“Momentive”), a company headquartered in Europe at 2 Shelbourne Buildings, Shelbourne Rd, Ballsbridge, Dublin 4, Ireland.

The legal basis for processing user data in connection with the surveys is our legitimate interest in obtaining feedback from our users regarding the quality of our services, in accordance with Article 6(1)(f) of the GDPR. If we ask users for consent to the processing of their data through the use of cookies, the legal basis for the processing is Article 6(1)(a) of the GDPR.

The integration takes place in so-called inline frames (IFrames), which can display external content from SurveyMonkey on our own website. When you visit a page on our website that contains a SurveyMonkey button, your browser establishes a direct connection to Momentive’s servers. The content of the IFrame is transmitted directly from Momentive to your browser and integrated into the webpage by your browser. We therefore have no influence over the type and scope of the data that Momentive collects, such as your IP address and cookies stored on your device.

For information on the purpose and scope of data collection, as well as the further processing and use of the data by Momentive, and your related rights and privacy settings, please refer to Momentive’s privacy policy at the following link:

https://www.surveymonkey.de/mp/legal/privacy/

9. Your Rights as a Data Subject

Every data subject has the right of access under Article 15 of the GDPR, the right to rectification under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to object under Article 21 of the GDPR, and the right to data portability under Article 20 of the GDPR. With regard to the right of access and the right to erasure, the restrictions set forth in Sections 34 and 35 of the Federal Data Protection Act (BDSG) apply. In addition, you have the right to lodge a complaint with a data protection supervisory authority (Article 77 of the GDPR in conjunction with Section 19 of the BDSG).

You may revoke any consent you have given to the processing of personal data at any time. This also applies to the revocation of consent given to us prior to the entry into force of the EU General Data Protection Regulation, i.e., before May 25, 2018. Please note that the withdrawal of consent takes effect only for the future. Processing that took place prior to the withdrawal is not affected by this.

10. Special Note Regarding Your Right to Object

In accordance with the provisions of Article 21 of the GDPR, we would like to draw your attention once again to your right to object as follows:

 

Information Regarding Your Right to Object Under Article 21 of the General Data Protection Regulation (GDPR)

Right to object on a case-by-case basis

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you that is carried out pursuant to Article 6(1)(e) of the GDPR (data processing in the public interest) and Article 6(1)(f) of the GDPR (data processing based on a balancing of interests). This also applies to profiling based on these provisions.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

The objection may be submitted in any form and should be sent by email to
datenschutz@easybell.de

11. Security Measures & Telecommunications-Specific Obligations

In accordance with Article 32 of the GDPR and Section 165 of the TKG, we implement appropriate technical and organizational measures to ensure the confidentiality, integrity, availability, and resilience of our systems and services. These include, among other things, access controls, encryption, regular security audits, and a documented security policy. In accordance with Section 19 of the German Telecommunications Data Protection Act (TTDSG), we uphold telecommunications secrecy and take special care to protect traffic and inventory data from unauthorized access, loss, or misuse.

12. Privacy Protection for End-User Devices

The processing of personal data in connection with the use and provisioning of telecommunications devices (e.g., routers, SIP phones) is carried out exclusively for the purpose of fulfilling the contract in accordance with Article 6(1)(b) of the GDPR, as well as on the basis of legitimate interests pursuant to Article 6(1)(f) of the GDPR (e.g., to ensure technical operation, IT security, and troubleshooting). Access to terminal equipment and the storage of information on such equipment take place only within the scope of Section 25 of the German Telesommunications Data Protection Act (TTDSG), to the extent that this is technically necessary or appropriate consent has been obtained.

Created on: 02. July 2026