Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to briefly as “data”) that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Effective date: October 21, 2025

Responsible Party

The data processing on this website is carried out by the website operator. You can find their contact details in the imprint of this website.

Email address: info@richardopokumedia.com

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of Data Processed

  • Inventory Data

  • Contact Data

  • Content Data

  • Usage Data

  • Meta/Communication Data

Categories of Data Subjects

  • Communication Partners

  • Users

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact inquiries and communication.
  • Direct marketing.
  • Management and response to inquiries.
  • Feedback.
  • Marketing.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Relevant legal bases

Below you will find an overview of the legal bases under the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or business may also apply. If, in individual cases, more specific legal bases are relevant, we will inform you of these in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of their personal data for a specific purpose or for multiple specific purposes.

  • Performance of a Contract and Pre-Contractual Requests (Art. 6(1)(b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to entering into a contract.

  • Legitimate Interests (Art. 6(1)(f) GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, override those interests.

In addition to the data protection provisions of the GDPR, national data protection regulations in Germany also apply. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG), which contains special provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated decision-making in individual cases including profiling. Furthermore, it regulates the processing of data for employment purposes (§ 26 BDSG), particularly with regard to the establishment, execution, or termination of employment relationships and the consent of employees. Additionally, state data protection laws of the individual federal states may also apply.

Security

In accordance with legal requirements and taking into account the state of the art, implementation costs, the nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of risks to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, transmission, availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data security incidents. In addition, we consider the protection of personal data during the development or selection of hardware, software, and procedures in accordance with the principles of data protection by design and by default.

SSL Encryption (https): To protect the data you transmit via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transfer of Personal Data

As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of such data may include, for example, service providers responsible for IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if processing occurs in the context of using third-party services or the disclosure or transfer of data to other individuals, entities, or companies, this is done only in accordance with legal requirements.

Except in cases of explicit consent or legally or contractually required transfers, we process or allow the data to be processed in third countries only if there is an adequate level of data protection, through contractual obligations using so-called standard contractual clauses of the EU Commission, in the presence of certifications, or through binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Deletion of Data

The data we process is deleted in accordance with legal requirements as soon as the consent permitting its processing is withdrawn or other legal authorizations no longer apply (e.g., if the purpose of processing the data no longer exists or the data is no longer required for that purpose). If the data is not deleted because it is necessary for other legally permissible purposes, its processing is restricted to those purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for asserting, exercising, or defending legal claims or for protecting the rights of another natural or legal person.

Furthermore, our privacy notices may include additional information regarding the retention and deletion of data, which take precedence for the respective processing activities.

Use of Cookies

Cookies are small text files or other storage markers that store information on end devices and read information from those devices. For example, they can store login status in a user account, the contents of a shopping cart in an online shop, accessed content, or used functions of an online service. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor traffic.

Consent Information: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is particularly not required if storing and reading information, including cookies, is strictly necessary to provide the user with an online service they have explicitly requested (i.e., our online offering). Revocable consent is clearly communicated to users and contains information about the respective use of cookies.

Legal Basis for Data Protection: The data protection legal basis on which we process users’ personal data using cookies depends on whether we request user consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, data processed using cookies is based on our legitimate interests (e.g., the business operation of our online offering and improving its usability) or, if necessary to fulfill our contractual obligations, when the use of cookies is required to fulfill our contractual duties. The purposes for which we process cookies are explained in this privacy policy or in the context of our consent and processing procedures.

Storage Duration: Regarding storage duration, the following types of cookies are distinguished:

  • Temporary Cookies (Session Cookies): Temporary cookies are deleted at the latest when a user leaves an online service and closes their device (e.g., browser or mobile application).

  • Permanent Cookies: Permanent cookies remain stored even after the device is closed. For example, login status can be retained or preferred content can be displayed immediately when a user revisits a website. Data collected via cookies can also be used to measure reach. If we do not provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and may be stored for up to two years.

General Information on Withdrawal and Objection (Opt-Out): Users can withdraw their consent at any time and also lodge an objection to processing in accordance with the legal provisions of Art. 21 GDPR. Users can also express their objection through their browser settings, e.g., by disabling the use of cookies (which may restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further Information on Processing Procedures, Methods, and Services:

Processing Cookie Data Based on Consent: We use a cookie consent management procedure, through which users’ consent to the use of cookies and the processing and providers mentioned in the cookie consent management procedure is obtained, managed, and can be revoked. The consent declaration is stored so that it does not need to be requested again and can be proven in accordance with legal obligations. Storage can occur server-side and/or in a cookie (so-called opt-in cookie or using similar technologies) to assign consent to a user or their device. Unless individual information is provided about the providers of cookie management services, the following applies: The consent may be stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and device used.

Provision of the Online Offering and Web Hosting

To provide our online offering securely and efficiently, we use the services of one or more web hosting providers, whose servers (or servers managed by them) are used to access the online offering. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security services and technical maintenance services.

The data processed in the context of providing the hosting services may include all information relating to users of our online offering that is generated during use and communication. This regularly includes the IP address, which is necessary to deliver online content to browsers, and any input made within our online offering or on websites.

Types of Data Processed:

  • Content Data: e.g., entries in online forms

  • Usage Data: e.g., visited webpages, interest in content, access times

  • Meta/Communication Data: e.g., device information, IP addresses

Data Subjects: Users (e.g., website visitors, users of online services)

Purposes of Processing:

  • Provision and user-friendliness of our online offering

  • Information technology infrastructure (operation and provision of information systems and technical devices, e.g., computers, servers)

Legal Basis: Legitimate interests (Art. 6(1)(f) GDPR)

Further Information on Processing Procedures, Methods, and Services:

Collection of Access Data and Log Files: We (or our web hosting provider) collect data on each access to the server (so-called server log files). Server log files may include the address and name of the requested websites and files, date and time of access, transmitted data volume, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability.

Legal Basis: Legitimate interests (Art. 6(1)(f) GDPR)

Deletion of Data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that must be retained for evidentiary purposes is exempt from deletion until the respective case is finally resolved.

Contact and Inquiry Management

When contacting us (e.g., via contact form, email, phone, or social media) as well as within the framework of existing user and business relationships, the information provided by the requesting individuals is processed to the extent necessary to respond to the inquiries and any requested actions.

Responding to inquiries and managing contact and inquiry data within contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre-)contractual requests, and otherwise based on our legitimate interests in responding to inquiries and maintaining user and business relationships.

Types of Data Processed:

  • Contact Data: e.g., email addresses, phone numbers

  • Content Data: e.g., entries in online forms

  • Usage Data: e.g., visited webpages, interest in content, access times

  • Meta/Communication Data: e.g., device information, IP addresses

Data Subjects: Communication partners

Purposes of Processing:

  • Provision of contractual services and customer support

  • Contact inquiries and communication

  • Management and response to inquiries

  • Feedback collection (e.g., via online forms)

  • Provision and usability of our online offering

Legal Basis:

  • Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR)

  • Legitimate interests (Art. 6(1)(f) GDPR)

Further Information on Processing Procedures, Methods, and Services:

Contact Form: When users contact us via our contact form, email, or other communication channels, we process the data provided to handle the communicated concern. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, to the extent necessary for their fulfillment, and otherwise based on our legitimate interests as well as the interests of the communication partners in responding to inquiries and our legal retention obligations.

Legal Basis: Performance of a contract and pre-contractual requests (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal authorization. If the content of a newsletter is specifically described during registration, this description is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and about us.

To register for our newsletters, it is generally sufficient to provide your email address. However, we may request a name for personal addressing in the newsletter or additional information if required for the purposes of the newsletter.

Double-Opt-In Procedure: Registration for our newsletter is generally conducted using a double-opt-in procedure. That means you will receive an email after registration asking you to confirm your subscription. This confirmation is necessary to prevent anyone from registering with someone else’s email address. Newsletter registrations are logged to be able to demonstrate compliance with legal requirements. This includes storing the registration and confirmation time as well as the IP address. Changes to the data stored by the email service provider are also logged.

Deletion and Restriction of Processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to prove previously given consent. Processing of this data is limited to the purpose of potentially defending claims. An individual deletion request can be made at any time, provided that the previous existence of consent is simultaneously confirmed. In cases where obligations to permanently observe objections exist, we reserve the right to store the email address solely for this purpose in a suppression list (so-called “blocklist”).

Logging of the registration process is based on our legitimate interests for the purpose of demonstrating proper procedure. If we engage a service provider to send emails, this is based on our legitimate interest in an efficient and secure mailing system.

Content:

  • Information about us, our services, promotions, and offers

Types of Data Processed:

  • Inventory Data: e.g., names, addresses

  • Contact Data: e.g., email addresses, phone numbers

  • Meta/Communication Data: e.g., device information, IP addresses

  • Usage Data: e.g., visited websites, interest in content, access times

Data Subjects: Communication partners

Purposes of Processing: Direct marketing (e.g., via email or postal mail)

Legal Basis: Consent (Art. 6(1)(a) GDPR)

Objection Possibility (Opt-Out): You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. A link to unsubscribe is provided at the end of each newsletter, or you can use one of the contact methods above, preferably email, to unsubscribe.

Further Information on Processing Procedures, Methods, and Services:

Measurement of Open and Click Rates: Newsletters contain a so-called “web beacon,” a pixel-sized file retrieved from our server, or if we use a mailing service provider, from their server, when the newsletter is opened. During this retrieval, technical information such as browser and system details, as well as your IP address and the time of access, is collected. This information is used to technically improve our newsletter based on technical data or target groups and their reading behavior, determined from access locations (identifiable via IP address) or access times.

Legal Basis: Consent (Art. 6(1)(a) GDPR).

Social Media Presence

We maintain online presences within social networks and process user data in this context to communicate with users active there or to provide information about us.

Please note that user data may be processed outside the European Union. This can pose risks for users, as it may make it more difficult to enforce their rights.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles can then be used to display advertisements within and outside the networks that are likely to match users’ interests. For these purposes, cookies are usually stored on users’ devices, storing information about user behavior and interests. Additionally, data may be stored in usage profiles independently of the devices used by the users (especially if users are members of the respective platforms and are logged in).

For detailed information on the respective processing methods and objection possibilities (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Even in cases of access requests or asserting data subject rights, please note that these can be most effectively exercised directly with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information. If you still require assistance, you may contact us.

Types of Data Processed:

  • Contact Data: e.g., email addresses, phone numbers

  • Content Data: e.g., entries in online forms

  • Usage Data: e.g., visited websites, interest in content, access times

  • Meta/Communication Data: e.g., device information, IP addresses

Data Subjects: Users (e.g., website visitors, users of online services)

Purposes of Processing: Contact inquiries and communication; feedback (e.g., collection of feedback via online forms); marketing

Legal Basis: Legitimate interests (Art. 6(1)(f) GDPR)

Further Information on Processing Procedures, Methods, and Services:

Instagram: Social network; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; legal basis: legitimate interests (Art. 6(1)(f) GDPR); website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.

Changes and Updates to the Privacy Policy

We ask that you regularly review the contents of our privacy policy. We update the privacy policy whenever changes in our data processing activities make it necessary. We will inform you if these changes require any action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that these addresses may change over time, and we ask you to verify the information before making contact.

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, in particular those set out in Articles 15 to 21 GDPR:

Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

Right to withdraw consent: You have the right to withdraw your consent at any time.

Right of access: You have the right to obtain confirmation as to whether or not data concerning you is being processed and, if so, to access this data and to receive further information and a copy of the data in accordance with legal requirements.

Right to rectification: You have the right, in accordance with legal requirements, to request the completion or correction of inaccurate data concerning you.

Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to request the immediate deletion of data concerning you, or alternatively, to request the restriction of processing of such data in accordance with legal requirements.

Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, or to request its transmission to another controller, in accordance with legal requirements.

Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of your personal data violates the provisions of the GDPR.

Definitions of Terms

This section provides an overview of the terminology used in this Privacy Policy. Many of these terms are taken from the law, particularly Article 4 of the GDPR. The legal definitions are binding. The following explanations are intended primarily to aid understanding. The terms are listed in alphabetical order.

Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Controller: The “controller” is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, such as collection, recording, organization, storage, adaptation, retrieval, use, disclosure, transmission, erasure, or destruction.