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Privacy Policy

Preamble 

With the following Privacy Policy, we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, the purposes for which we process it, and the scope of such processing. This Privacy Policy applies to all processing of personal data carried out by us, both in connection with the provision of ourservices and, in particular, on our websites, in mobile applications, and on external online platforms, such as our social media profiles (hereinafter collectively referred to as the “Online Offer”). 

Effective: August 4, 2026 


Data Controller 

documenta and Museum Fridericianum gGmbH 
Friedrichsplatz 18 
34117 Kassel 
T +49 561 70727-0 
F +49 561 70727-39 
Legal Notice
 
You can reach our Data Protection Officer using the following contact information: 
 
You can contact our external data protection officer, Dr. Blazy (GDPC GbR), by phone at +49 (0) 561 830 99 165, by mail at the address listed above with the note “Data Protection Officer,” or by email at datenschutzbeauftragter@documenta.de. 


Applicable Legal Bases 

Applicable Legal Bases Under the General Data Protection Regulation (GDPR): The following provides 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 may apply in your country of residence or our country of incorporation. Furthermore, should more specific legal bases apply in individual cases, we will inform you of these in the Privacy Policy. 

  • Consent (Art. 6(1), first sentence, lit. a) GDPR) – The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes. 

  • Performance of a Contract and Pre-Contractual Inquiries (Art. 6(1), first sentence, lit. b) GDPR) — The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request. 

  • Legal obligation (Art. 6(1), first sentence, lit. c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject. 

  • Legitimate Interests (Art. 6(1), sentence 1, subparagraph (f) of the GDPR) – Processing is necessary to safeguard the legitimate interests of the controller or a third party, provided that the interests, fundamental rights, and fundamental freedoms of the data subject that require the protection of personal data do not take precedence. 

Note on the Applicability of the GDPR and the Swiss Data Protection Act (DSG): This privacy notice serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are employed here due to its broadergeographical scope and clarity. In particular, instead of the terms “processing” of “personal data,” “overriding interest,” and “personal data requiring special protection” used in the Swiss Data Protection Act (DSG), the terms “processing” of “personal data,” “legitimate interest,” and “special categories of data” used in the GDPR are employed. However, the legal meaning of these terms continues to be determined in accordance with the Swiss Data Protection Act (DSG) within the scope of its applicability. 

Applicability of Data Protection Requirements in the Country of Establishment: In the country where the controller is established, national data protection regulations apply in addition to the General Data Protection Regulation (GDPR). 


Security Measures 

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

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, and disclosure of the data, ensuring its availability, and maintaining its separation. Furthermore, we have established procedures that ensure the exercise of datasubjects’ rights, the erasure of data, and responses to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technical design and privacy-friendly default settings. 

Securing Online Connections Using TLS/SSL Encryption Technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we rely on TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologiesencrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of “HTTPS” in the URL. This serves as an indicator to users that their data is being transmitted securely and in encrypted form. 


Transfer of Personal Data 

As part of our processing of personal data, it may occur that such data is transferred to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers contracted to perform IT tasks or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.


International Data Transfers 

Data Processing in Third Countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if such a transfer occurs in connection with the use of third-party services or the disclosure or transfer of data to other entities or entities, or companies (which can be identified by the postal address of the respective provider or if the privacy policy expressly refers to data transfers to third countries), this is always done in accordance with legal requirements. 

For data transfers to the United States, we primarily rely on the Data Privacy Framework (DPF), which was recognized as a secure legal framework by an adequacy decision of the European Commission dated July 10, 2023. In addition, we have entered into standard contractual clauses with the respective providers that comply with the EU Commission’s requirements and establish contractual obligations to protect your data. 

This two-tiered safeguard ensures comprehensive protection of your data: The DPF serves as the primary layer of protection, while the Standard Contractual Clauses provide additional security. Should any changes occur within the framework of the DPF, the Standard Contractual Clauses serve as a reliable fallback option. In this way, we ensure thatyour data remains adequately protected at all times, even in the event of political or legal changes. 

For each service provider, we inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English). 

For data transfers to other third countries, appropriate safeguards apply, in particular standard contractual clauses, explicit consent, or transfers required by law. Information on transfers to third countries and applicable adequacy decisions can be found on the European Commission’s website: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. 


Rights of Data Subjects 

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 through 21 of the GDPR: 

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for the purposeof direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of 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 any consent you have given at any time. 

  • Right of Access: You have the right to request confirmation as to whether data concerning you is being processed, as well as access to this data, further information, and a copy of the data in accordance with legal requirements. 

  • Right to Rectification: In accordance with legal requirements, you have the right to request that data concerning you be completed or that inaccurate data concerning you be corrected. 

  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay or, alternatively, to request a restriction on the processing of such data in accordance with legal requirements. 

  • Right to Data Portability: You have the right, in accordance with legal requirements, to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or to request that it be transmitted to another data controller. 

  • Complaint to a Supervisory Authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority—in particular, a supervisory authority in the Member State where you habitually reside— the supervisoryauthority of your place of work or the location of the alleged infringement, if you believe that the processing of your personal data violates the GDPR. 

Provision of the Online Service and Web Hosting 

We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device. 

  • Types of data processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved). Log data (e.g., log files regarding logins, data retrieval, or access times). 

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

  • Purposes of processing and legitimate interests: Provision of our online services and user-friendliness; IT infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Security measures. 

  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” 

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

Further information on processing operations, procedures, and services 

  • Provision of Online Services on Leased Storage Space: To provide our online services, we use storage space, computing capacity, and software that we lease or otherwise obtain from a server provider (also known as a “web host”). 

  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files.” Server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user’soperating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes—for example, to prevent server overload (particularly in the event of malicious attacks, known as DDoS attacks)—and, on the other hand, to ensureserver capacity and stability. Data Deletion: Log file information is stored for a maximum of 30 days and is then deleted or anonymized. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved. 

  • Hetzner: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacity); Service Provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany; Website: https://www.hetzner.com; Privacy Policy: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner. Data Processing Agreement: https://docs.hetzner.com/de/general/company-and-policy/data-protection-at-hetzner. 

  • Use of the “Kirby” Content Management System: We use the Kirby content management system, provided by Content Folder GmbH & Co. KG, Germany, to operate this website. Personal data is processed solely for the purpose of providing the content of our website and ensuring its secure and stable display. Kirby is hosted locally on the controller’s servers. When using Kirby, the following data may be processed depending on technical requirements: server and access data (IP address, time of server request, HTTP status codes, technical browser information, operating system, referrer URL), system and error logs used for diagnostics and security analysis, and form data if you enter information via an embedded contact or registration form. Legal bases: Art. 6(1)(f) GDPR (legitimate interest)—our interest lies in the secure and efficient provision of the website, as well as in technical stability and the documentation of security-related incidents (this applies in particular to the setting of cookies as part of CSRF protection; see the section “Use of Cookies” for details); Art. 6(1)(b) GDPR, provided that you submit data via forms that is necessary for the performance of a contract or for entering into a contract. If, within the scope of the CMS,information is stored on or read from your devices that is not necessary for the use of our website, we will obtain your separate consent for this in accordance with Art. 6(1)(a) GDPR / § 25(1) TDDDG. Retention period: Server log files are stored for a maximum of 30 days in accordance with our security and compliance requirements and are subsequently deleted or anonymized, unless longer retention is necessary to investigate security-related incidents.


Use of Cookies 

The term “cookies” refers to functions that store and retrieve information on users’ devices. Cookies may also be used for various purposes, such as ensuring the functionality, security, and convenience of online services, as well as analyzing visitor traffic. We use cookies in accordance with legal requirements. To this end, we obtain users’ consentin advance when necessary. If consent is not required, we rely on our legitimate interests. This applies when the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent may berevoked at any time. We provide clear information about the scope of our use and which cookies are used. 

  • Use of a technically necessary cookie to protect against Cross-Site Request Forgery (CSRF). To secure our forms against so-called Cross-Site Request Forgery (CSRF) attacks—that is, attempts to submit forms via our website on your behalf without your knowledge—we use a session cookie from our self-hosted content management system(Kirby). This cookie (kirby_session) contains a randomly generated session ID, which is used to verify a previously issued, hidden security token on the server side when a form is submitted. No content from your form entries is stored in the cookie. The cookie data is not transferred to third-party servers; processing takes place exclusively on ourown, self-operated server. We base the processing of personal data (session ID) carried out in connection with this cookie on Art. 6(1)(f) GDPR in conjunction with § 25(2)(2) TDDDG. Our legitimate interest lies in ensuring the security and proper functioning of the form you have accessed, as well as in protecting against fraudulent form submissions made under someone else’s name. 

Notes on the legal basis under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures. 

Retention Period: With regard to the retention period, the following types of cookies are distinguished: 

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their device (e.g., browser or mobile app). 

  • Persistent cookies: Persistent cookies remain stored even after the device is closed. This allows, for example, the login status to be saved and preferred content to be displayed immediately when the user visits a website again. Likewise, user data collected via cookies may be used for audience measurement. Unless we provide users withexplicit information regarding the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these cookies are permanent and may be stored for up to two years. 

General Information on Withdrawal of Consent and Objection (Opt-out): Users may withdraw the consent they have provided at any time and may also object to the processing of their data in accordance with legal requirements, including through their browser’s privacy settings. 

  • Types of Data Processed: Meta data, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved). 

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

  • Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR). 

Overview of cookies used:

Essential

These cookies enable basic functions necessary for the operation of the website. 

  • kirby_session – Provider: Website operator. Used to protect forms from malicious requests (CSRF protection). Storage duration: up to 2 hours; the session expires after 30 minutes of inactivity. 

  • d16_simple_design – Provider: Website operator. Stores whether the “Simple Design” feature has been enabled. Storage duration: permanently or until manually deleted in the browser. 

  • d16_reduced_motion – Provider: Website operator. Stores whether the “Reduced Motion” feature has been enabled. Storage duration: permanently or until manually deleted in the browser. 

  • d16_consent – Provider: Website operator. Stores the selection made in the consent dialog, the time of the decision, and the version of the consent prompt. Purpose: To apply and document the selected settings and to prevent the prompt from reappearing. Storage period: twelve months. No transfer to third parties. 

Functionality 

These cookies enable basic interactions and functions that allow you to access selected features of our website and facilitate your communication with us. 

  • d16_layout_grid – Provider: Website operator. Stores whether the layout grid for visually reviewing the page design has been activated. Storage period: 1 year. 

Measurement (Analytics and Performance Cookies) 

These cookies help us measure traffic and analyze your behavior to improve our service. 

For statistical reach measurement, we use Matomo in a cookie-free configuration. No analytics or performance cookies are stored on your device. 

Marketing and Tracking 

These cookies track behavior across pages. They enable us to display relevant advertisements and allow for targeted communication. 

  • YouTube – Provider: Google Ireland Limited. Used to provide embedded videos, as well as for security, storing playback settings, measuring reach, and potential personalization. The following cookies may be used in particular: YSC (session), __Secure-YNID (6 months), VISITOR_INFO1_LIVE (6 months), VISITOR_PRIVACY_METADATA (6 months), __Secure-ROLLOUT_TOKEN (6 months), PREF (8 months), pm_sess (30 minutes), AEC (6 months), SOCS (13 months), and __Secure-YENID (13 months). The cookies are not set or transmitted until after you have selected “Load Video.” 

  • Vimeo – Provider: Vimeo.com, Inc. Used to provide embedded videos, store player settings, ensure security, and analyze usage. The following cookies may be used in particular: vuid (2 years), player and flags (1 year each), player_clearance (7 days), __cf_bm (30 minutes),_cfuvid (session), and cf_clearance (1 year). These cookies are only setor transmitted after you select “Load Video.”  

Further information on processing procedures, methods, and services: 

  • Processing of cookie data based on consent: We use a consent management solution developed in-house to obtain users’ consent to the use of cookies or to the procedures and providers specified within the consent management solution. This procedure serves to obtain, log, manage, and revoke consents, particularly with regard to the useof cookies and similar technologies that are used to store, read, and process information on users’ devices. As part of this process, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing activities and providers listed in the consent management process. Users also havethe option to manage and revoke their consents. The consent declarations are stored to avoid repeated prompts and to maintain proof of consent in accordance with legal requirements. The categories selected by the website visitor, the time of the decision, and the version of the consent prompt are stored exclusively in a first-party cookie. Consent is stored for a period of one year. There is no separate server-side logging of consent or transmission to an external CMP provider. User IDs, IP addresses, and browser, system, or device information are not stored.  


Contact and Inquiry Management 

When you contact us (e.g., by mail, contact form, email, phone, or social media), as well as in the context of existing user and business relationships, the information provided by the individuals making the inquiry is processed to the extent necessary to respond to contact requests and any requested actions. 

  • Types of data processed: Contact data (e.g., mailing and email addresses or phone numbers); content data (e.g., text or image-based messages and posts, as well as related information, such as details regarding authorship or the time of creation). Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved). 

  • Data subjects: Communication partners. 

  • Purposes of processing and legitimate interests: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via an online form). Provision of our online services and user-friendliness. 

  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” 

  • Legal bases: Legitimate interests (Art. 6(1), first sentence, lit. f) of the GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1), first sentence, lit. b) of the GDPR). 

Additional Information on Processing Activities, Procedures, and Services: 

  • Contact Form: When you contact us via our contact form, by email, or through other communication channels, we process the personal data you provide to respond to and handle your inquiry. This typically includes information such as your name, contact information, and, if applicable, any additional information provided to us that is necessary for proper processing. We use this data exclusively for the stated purpose of establishing contact and communication. 

Honeypot Method Against Spam Bots 

To detect and prevent automated form submissions by so-called spam bots, we use a so-called honeypot field in our forms. This is a form field that is invisible to human visitors but is submitted along with the other form fields. While humans naturally do not fill out this field, automated scripts (bots) often enter data even into such hidden fields. If the honeypot field is recognized as filled out during processing on our server, we interpret this as an indication of an automated submission not initiated by a human. In this case, we do not process the form submission further. The data entered in the honeypot field is not transferred to third-party servers; the check is performed exclusively on our own server. 

  • Legal basis: Processing is based on our legitimate interests pursuant to Art. 6(1)(f) of the GDPR. Our legitimate interest lies in protecting our forms from abusive, automated use (e.g., spam or attempted attacks) and in ensuring the functionality and security of our services. The honeypot field is evaluated exclusively on the server side. No information is stored on your device, and no information already stored on your device is read; therefore, consent under § 25 TDDDG is not required for this function. 

  • Recipients: The data collected as part of the honeypot process is not disclosed to third parties. 

  • Retention Period : No data is stored 


Newsletters and Electronic Notifications 

We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) exclusively with the recipients’ consent or on a legal basis. If the content of the newsletter is specified during the subscription process, this content is decisive for the users’ consent. To subscribe to our newsletter, providing your email address is usually sufficient. However, in order to offer you a personalized service, we may ask you to provide your name so we can address you personally in the newsletter, or to provide additional information if it is necessary for the purpose of the newsletter. 

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 be able to prove that consent was previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for deletion is possible at any time, provided that the prior existence of consent is confirmed at the same time. In the event of obligations to permanently honor objections, we reserve the right to store the email address solely for this purpose in a blocklist. 

The registration process is logged based on our legitimate interests for the purpose of verifying that it was carried out properly. To the extent that we engage a service provider to send emails, this is done based on our legitimate interests in an efficient and secure mailing system. 

Content 

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

  • Types of data processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., mailing and email addresses or phone numbers); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved). Usage data (e.g., page views and time spent on pages, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). 

  • Data subjects: Communication partners. 

  • Purposes of processing and legitimate interests: Direct marketing (e.g., via email or mail). Audience measurement (e.g., access statistics, identification of returning visitors). 

  • Legal bases: Consent (Art. 6(1), sentence 1, letter a) of the GDPR). Legitimate interests (Art. 6(1), sentence 1, letter f) of the GDPR). 

  • Opt-Out Option: You may unsubscribe from our newsletter at any time, i.e., revoke your consent or opt out of receiving future issues. You will find a link to unsubscribe from the newsletter at the end of each issue, or you may use any of the contact options listed above—preferably email—to do so. 

Additional Information on Processing Activities, Procedures, and Services: 

  • Measuring Open and Click-Through Rates: The newsletters contain so-called “web beacons”—that is, a pixel-sized file that is retrieved from our server or the server of our mailing service provider (if we use one) when you open the newsletter. As part of this retrieval, technical information—such as details about your browser and system—as well as your IP address and the time of retrieval are initially collected. This information is used to technically improve our newsletter based on technical data or by analyzing target groups and their reading behavior based on their locations (which can be determined using the IP address) or access times. This analysis also includes determiningwhether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until it is deleted. The analyses serve to identify our users’ reading habits and tailor our content to them, or to send different content based on our users’ interests. The measurement of open and click-through rates, as well as the storage of the measurement results in users’ profiles and their further processing, are based on the users’ consent. Unfortunately, it is not possible to revoke consent for performance measurement separately; in this case, the entire newsletter subscription must be canceled or opt-out. In that case, the stored profile information will be deleted; legal basis: consent (Art. 6(1), sentence 1, lit. a) GDPR). 


Web Analytics, Monitoring, and Optimization 

Web analytics (also referred to as “reach measurement”) is used to evaluate visitor traffic to our online offering and may include pseudonymized data on visitors’ behavior, interests, or demographic information, such as age or gender. With the help of reach analysis, we can, for example, determine at what times our online offering or its featuresand content are used most frequently, or encourage repeat visits. It also enables us to identify which areas require optimization. 

In addition to web analytics, we may also use testing methods to, for example, test and optimize different versions of our online offering or its components. 

Unless otherwise specified below, profiles—that is, data aggregated for a specific usage session—may be created for these purposes, and information may be stored in a browser or on a device and then retrieved. The data collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and details regarding usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible. 

In addition, users’ IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by truncating the IP address) to protect users. In general, no personally identifiable user data (such as email addresses or names) is stored in the context of web analytics, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software we use know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective processes. 

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we would also like to draw your attentionto the information regarding the use of cookies in this Privacy Policy. 

  • Types of Data Processed: Usage data (e.g., page views and time spent on the site, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved). 

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

  • Purposes of processing and legitimate interests: Audience measurement (e.g., access statistics, identification of returning visitors); profiles containing user-related information (creation of user profiles). Provision of our online services and user-friendliness. 

  • Retention and deletion: Deletion in accordance with the information in the section “General Information on Data Storage and Deletion.” Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years.). 

  • Security measures: IP masking (pseudonymization of the IP address). 

  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures, and services  

  • Matomo ( without cookies ): Matomo is a privacy-friendly web analytics software that operates without cookies and identifies returning users using a so-called “digital fingerprint,” which is stored anonymously and updated every 24 hours; With the “digital fingerprint,” user activity within our online service is tracked using pseudonymized IP addresses in combination with the user’s browser settings in such a way that it is not possible to draw conclusions about the identity of individual users. The user data collected through the use of Matomo is processed solely by us and is not shared with third parties; Website: https://matomo.org/. Security measures: IP masking (pseudonymization of the IP address).  


Social Listening / Press Clipping 

Meltwater – Social Listening Tool / Press Clipping Tool 

We use the Meltwater service provided by Meltwater Deutschland GmbH, Unter den Linden 21, 10117 Berlin, to perform the following: 

  • Social Listening: Analysis of publicly available content on social networks, blogs, forums, news sites, etc. 

  • Media Monitoring / Press Clipping: Collection and analysis of press releases and online media coverage regarding our company, our brands, or relevant topics. 

Purposes of processing: 

  • Reputation management and strategic communication planning 

  • Market and trend analyses 

  • Identification of public sentiment 

  • Evaluation of PR and marketing measures 

Legal basis: 

The processing of personal data in the context of social listening and media monitoring is based on Article 6(1)(f) of the GDPR (legitimate interest). Our legitimate interest lies in effective public relations, the analysis and improvement of our communication strategies, and the protection of our corporate image. 

The data processed is derived from publicly available sources, in particular: 

  • Social networks (e.g., Twitter/X, Instagram, Facebook—provided they are publicly viewable) 

  • Online media and news sites 

  • Blogs, forums, video platforms, and comment sections 

  • Websites (worldwide), provided there is a connection to our company and our activities 

Meltwater selects these sources in accordance with a contractual agreement. Depending on the context of the publication, the following personal data may be processed: 

  • Name or username of the person making the post (e.g., author of a post) 

  • Content of the publication (text, images, videos, audio if applicable) 

  • Date and time of publication 

  • Source / URL 

  • Language and, if applicable, location (if publicly visible or provided) 

We do not engage in any further profiling and do not link this data to other personal information. 

The data is processed by Meltwater Deutschland GmbH on our behalf. Meltwater acts as a data processor in accordance with Article 28 of the GDPR. A corresponding contractual agreement is in place. Data is only disclosed to third parties if this is necessary to fulfill the stated purposes or if there are legal obligations to do so. 

The data is stored only for as long as necessary for the stated purposes. The retention period for data collected by Meltwater varies depending on the type of content: 

  1. Editorial content (news): Stored until the year 2009 

  2. Social media content: This is stored for a rolling period of 15 months. 

  3. Specific social media platforms: 
    • Facebook: 450 days (15 months) of historical data following authentication. 
    • YouTube: 30 days for videos and comments. 
    • Comments on websites: 15 months. 

The maximum search period for news and social media content is one year in each case. 

After the specified periods have expired, the data is automatically deleted, or upon request. 


Social Media Presence 

We maintain online presences on social media platforms and, in this context, process user data to communicate with users active on those platforms or to provide information about us. 

Please note that user data may be processed outside the European Union in this context. This may pose risks to users, as it could, for example, make it more difficult to enforce user rights. 

Furthermore, user data within social media platforms is generally processed for market research and advertising purposes. For example, usage profiles may be created based on users’ behavior and the resulting interests. These profiles may in turn be used, for instance, to display advertisements within and outside the platforms that are presumedto correspond to users’ interests. For this reason, cookies are typically stored on users’ computers to record their usage behavior and interests. In addition, usage profiles may also store data regardless of the devices used by users (particularly if they are members of the respective platforms and are logged in there). 

For a detailed description of the respective forms of processing and the options for opting out, please refer to the privacy policies and information provided by the operators of the respective networks. 

We also note that requests for information and the exercise of data subject rights are most effectively handled directly with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need assistance, however, you may contact us. 

  • Types of data processed: Contact information (e.g., mailing and email addresses or phone numbers); Content data (e.g., text or image-based messages and posts, as well as related information such as details regarding authorship or the time of creation); Usage data (e.g., page views and time spent on pages, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Meta, communication, and process data (e.g., IP addresses, timestamps, identification numbers, individuals involved). Master data (e.g., full name, residential address, contact information, customer number, etc.). 

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

  • Purposes of processing and legitimate interests: Communication; feedback (e.g., collecting feedback via an online form); public relations; marketing. Provision of our online services and user-friendliness. 

  • Retention and deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” 

  • Legal bases: Legitimate interests (Art. 6(1), sentence 1, lit. f) GDPR). Consent (Art. 6(1), sentence 1, lit. a) GDPR). 

Additional information on processing activities, procedures, and services: 

  • Instagram: Social network that allows users to share photos and videos, comment on and like posts, send messages, and follow profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/. 

  • Facebook Pages: Profiles within the Facebook social network—We are jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data from visitors to our Facebook page (“Fan Page”). This includes, in particular, information about user behavior (e.g., content viewed or interacted with, actions taken) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). Further details can be found in Facebook’s Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical analyses via the “Page Insights” service, which provide information on how peopleinteract with our page and its content. This is based on an agreement with Facebook (“Information on Page Insights”: https://www.facebook.com/legal/terms/page_controller_addendum), which governs, among other things, security measures and the exercise of data subjects’ rights. Further information can be found here:https://www.facebook.com/legal/terms/information_about_page_insights_data. Users may therefore direct requests for access or deletion directly to Facebook. Users’ rights (in particular the right to access, erasure, objection, and the right to lodge a complaint with a supervisory authority) remain unaffected by this. Joint responsibility islimited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including any potential transfer to Meta Platforms Inc. in the U.S.; service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; website:https://www.facebook.com. Privacy Policy: https://www.facebook.com/privacy/policy/. 

  • LinkedIn: Social Network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to generate “Page Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as the actions theytake. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job title, country, industry, hierarchical level, company size, and employment status. Privacy information regarding LinkedIn’s processing of user data can be found in LinkedIn’s Privacy Policy: https://www.linkedin.com/legal/privacy-policy. 
    We have entered into a specific agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum,” https://legal.linkedin.com/pages-joint-controller-addendum), which specifically outlines the security measures LinkedIn must adhere to and in which LinkedIn has agreed to honor the rights of data subjects (i.e., users can, for example, submit requests for access or deletion directly to LinkedIn). Users’ rights (in particular the right to access, erasure, objection, and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly with regard to the transfer of data to the parent company, LinkedIn Corporation, in the United States; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Website:https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy. Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. 

  • TikTok: Social network that allows users to share photos and videos, comment on and favorite posts, send messages, and follow accounts; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Website: https://www.tiktok.com; Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. Data Processing Agreement: Provided by the service provider. 

  • TikTok Business: A social network that allows users to share photos and videos, comment on and favorite posts, send messages, and follow accounts—We and TikTok are jointly responsible for the collection and transmission of event data, as well as for measuring and generating insights reports (statistics) for profile owners. This event dataincludes information about the types of content users view or interact with, or the actions they take, as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from users’ profiles, such as country or location. Privacy information regarding TikTok’sprocessing of user data can be found in TikTok’s Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/de. We have entered into a specific joint controller agreement with TikTok, which specifically outlines the security measures TikTok must adhere to and in which TikTok has agreed to fulfill data subject rights (i.e., users can, for example, submit requests for information or deletion directly to TikTok). Users’ rights (in particular the rights to access, erasure, objection, and filing a complaint with the competent supervisory authority) are not restricted by the agreements with TikTok. The joint controller agreement can be found in TikTok’s “Jurisdiction Specific Terms”:https://ads.tiktok.com/i18n/official/policy/jurisdiction-specific-terms.; Service providers: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Website: https://www.tiktok.com. Privacy Policy:https://www.tiktok.com/legal/page/eea/privacy-policy/de. 

  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Privacy Policy: https://business.safety.google/privacy/. Opt-out option: https://myadcenter.google.com/. 


Plug-ins, Embedded Features, and Content 

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or maps (hereinafter collectively referred to as “content”). 

This integration always requires that the third-party providers of this content process the user’s IP address, as they would be unable to send the content to the user’s browser without it. The IP address is therefore necessary for displaying this content or these features. We make every effort to use only content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These “pixel tags” allow information—such as visitor traffic on the pages of this website—to be analyzed. This pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, the time of the visit, and other details regarding the use of our online service; it may also be linked to such information from other sources. 

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is this consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., our interest in providing efficient, cost-effective, and user-friendly services). In this context, we would also like to draw yourattention to the information regarding the use of cookies in this Privacy Policy. 

  • Types of Data Processed: Usage data (e.g., page views and time spent on pages, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and features). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, individuals involved). 

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

  • Purposes of processing and legitimate interests: Provision of our online offerings and user-friendliness; audience measurement (e.g., access statistics, identification of returning visitors); tracking (e.g., interest-based/behavioral profiling, use of cookies); target group segmentation. Marketing. 

  • Retention and Deletion: Deletion in accordance with the information provided in the section “General Information on Data Storage and Deletion.” Storage of cookies for up to 2 years (Unless otherwise specified, cookies and similar storage methods may be stored on users’ devices for a period of two years.). 

  • Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR). 

Further information on processing operations, procedures, and services: 


Data Protection for Job Applications and the Application Process 

The primary purpose of data processing is to conduct and manage the application process and to assess your suitability for the position in question. Consequently, the processing of your applicant data is necessary to make a decision regarding the establishment of an employment relationship and, thereby, your hiring. The primary legal basis for this is Article 6(1)(b) of the GDPR. The processing of special categories of personal data—to the extent necessary for the decision regarding hiring—is based on Article 9(1) of the GDPR. If you have voluntarily provided us with special categories of personal data whose processing is not necessary for the decision regarding hiring, the collection and processing are based on the consent you provided upon submission. We also collect and process personal data from applicants on the basis of legitimate interests to defend against legal claims (in particular under the AGG) in accordance with Article 6(1), sentence 1, subparagraph (f) of the GDPR. Processing may also take place electronically. This isparticularly the case when an applicant submits the relevant application documents to us electronically, for example via email. We have set up a dedicated email address for applications submitted via email (bewerbung@documenta.de). If we enter into an employment contract with an applicant, the data provided will be stored for the purpose of administering the employment relationship in compliance with applicable legal requirements. If no such contract is concluded with the applicant, the application documents will be automatically deleted no later than 6 months after notification of the rejection decision, provided that no other legitimate interests on our part preclude such deletion. An example of an “other legitimate interest” in the sense mentioned above is, for instance, the burden of proof in proceedings under the General Equal Treatment Act (AGG). 


Privacy Notice for Participation in Events 

We process the personal data you provide to us as part of the registration process for the purpose of preparing and conducting the respective event, as well as for capacity planning, based on the consent you provided upon registration in accordance with Article 6(1)(a) of the GDPR and, depending on the type of event, based on a contract pursuantto Article 6(1)(b) of the GDPR. You may revoke your consent at any time with future effect. Revocation means that we can no longer use your personal data for the event—which requires registration—and your participation in the event is therefore precluded. 

To the extent necessary, we process your data beyond the scope of your consent pursuant to Article 6(1)(f) of the GDPR to safeguard our legitimate interests or those of third parties, such as for the purpose of defending ourselves in legal disputes. Please note that photographs and/or video recordings are taken at our events, and that the imageand/or video material may be published on the Internet, on websites operated by documenta and Museum Fridericianum gGmbH or their cooperation partners, on social media, and/or in one of the publications of documenta and Museum Fridericianum gGmbH or their cooperation partners for public relations purposes (in particular, reporting) on the respective event. 

By participating in the event, you consent to the publication of photographs and video recordings taken during the event (Sections 22, 23 of the German Artistic Publicity Act (KUG)). The collection—including the taking of photographs and their processing—is carried out for the purpose of illustrated reporting based on Article 6(1), sentence 1, letterf of the GDPR. Please note that, pursuant to Article 21(1) of the GDPR, you may object to this processing on grounds relating to your particular situation. We will then 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 must be sent to the address listed above. 

Please be advised that, as part of the documentation of the event, data of archival value may be generated, which may be added to the holdings of the documenta archive. If archival materials contain your personal data, we process this data on the basis of Article 6(1)(c) of the GDPR in conjunction with Sections 7, 8, and 11 of the HArchivG. Weprocess any special categories of personal data that may be processed in this context on the basis of Section 25 of the HDSIG. 

If you have any questions regarding this information, including your (data protection) rights, you may also contact our Data Protection Officer. 


Changes and Updates 

We ask that you review the content of our Privacy Policy regularly. We will update the Privacy Policy as soon as changes to our data processing activities make this necessary. We will notify you as soon as the changes require 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 that you verify the information before contacting them. 


Definitions of Terms 

This section provides an overview of the terms used in this Privacy Policy. To the extent that these terms are defined by law, their legal definitions apply. The explanations below, however, are primarily intended to aid understanding. 

  • Employees: Employees are defined as individuals who are in an employment relationship, whether as staff members, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is established by an employment contract or agreement. It includes the employer’sobligation to pay the employee compensation in exchange for the employee’s work. The employment relationship encompasses various phases, including the establishment phase, during which the employment contract is concluded; the performance phase, during which the employee performs their work; and the termination phase, whenthe employment relationship ends, whether through termination, a mutual termination agreement, or otherwise. Employee data refers to all information relating to these individuals and pertaining to their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data, and performance evaluations. 

  • Master data: Master data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include, among other things, personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling unique identification and communication. 

  • Content data: Content data encompasses information generated during the creation, editing, and publication of all types of content. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates. 

  • Contact data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, phone numbers, mailing addresses, and email addresses, as well as communication channels such as social media handles and instant messaging identifiers. 

  • Meta, communication, and operational data: Meta, communication, and operational data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. It may include details on filesize, creation date, the author of a document, and revision histories. Communication data captures the exchange of information between users via various channels, such as email correspondence, call logs, social media messages, and chat histories, including the individuals involved, timestamps, and transmission methods. Process datadescribes the processes and procedures within systems or organizations, including workflow documentation, transaction and activity logs, as well as audit logs used to track and verify operations. 

  • Usage data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information that reveals how users utilize applications, which features they prefer, how long they stay on specific pages, and the paths they take when navigating through an application. Usage data may also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings 

  • Personal Data: “Personal data” refers to any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie) or one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. 

  • Profiles containing user-related information: The processing of “profiles containing user-related information,” or “profiles” for short, encompasses any form of automated processing of personal data that involves using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.), or to predict them (e.g., interests in specific content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes. 

  • Log data: Log data consists of information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details regarding the use or operation of a system. Log data is often used to analyze system issues, monitor security, or generate performance reports. 

  • Audience measurement: Audience measurement (also known as web analytics) is used to evaluate visitor traffic to an online service and may include the behavior or interests of visitors regarding specific information, such as website content. With the help of audience analysis, operators of online services can, for example, determine at whattimes users visit their websites and what content they are interested in. This enables them, for example, to better tailor the content of their websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to identify returning visitors and thus obtain more accurateanalyses of the use of an online service. 

  • Tracking: The term “tracking” refers to the ability to track users’ behavior across multiple online services. As a rule, behavioral and interest-based information regarding the online services used is stored in cookies or on the servers of the providers of tracking technologies (so-called “profiling”). This information can then be used, for example, to display advertisements to users that are likely to match their interests. 

  • Data Controller: The term “data controller” refers to the natural or legal person, public authority, agency, or other body that, 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 performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collection, evaluation, storage, transmission, or deletion. 

  • Target Audience Creation: The term "Custom Audiences" refers to the process of defining target audiences for advertising purposes, such as displaying ads. For example, based on a user’s interest in certain products or topics online, it can be inferred that this user would be interested in ads for similar products or the online store where theyviewed those products. The term “Lookalike Audiences” (or similar target groups) is used when content deemed suitable is displayed to users whose profiles or interests are presumed to match those of the users whose profiles were used to create the audience. Cookies and web beacons are typically used for the purpose of creating Custom Audiences and Lookalike Audiences.