Privacy policy

I. Name and address of the controller

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

SVIX Media
Owner: Konstantin Botschmanowski
Schulstraße 72
41372 Niederkrüchten
Germany
Email: hello@kosten.org

II. General information on data processing

1. Scope of the processing of personal data

As a rule, we only process our users' personal data to the extent necessary to provide a functional website as well as our content and services. For each processing operation, the following sections state the legal basis; we obtain consent where it is required.

2. Legal basis for the processing of personal data

Where we obtain the data subject's consent for processing operations involving personal data, Art. 6 (1) (a) GDPR serves as the legal basis. Where the processing of personal data is necessary for the performance of a contract to which the data subject is party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations necessary to take steps prior to entering into a contract. Where processing is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis. Where vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis. If processing is necessary for the purposes of a legitimate interest of our company or a third party, and the interests, fundamental rights and freedoms of the data subject do not override that interest, Art. 6 (1) (f) GDPR serves as the legal basis for the processing.

3. Erasure of data and storage period

The data subject's personal data is erased or blocked as soon as the purpose of storage no longer applies. Data may also be stored beyond this if provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. Data is also blocked or erased when a storage period prescribed by these provisions expires, unless further storage is necessary for the conclusion or performance of a contract. Statutory retention periods under the German Commercial Code (6 years, § 257 HGB) and the German Fiscal Code (10 years, § 147 AO) remain unaffected.

III. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing device. The following data is collected: (1) the user's IP address, (2) the date and time of access, (3) the address requested and the HTTP status code, (4) the amount of data transferred, (5) the website from which access is made (referrer), (6) browser type, browser version and operating system (user agent). The data is stored in our system's log files. This data is not stored together with other personal data of the user.

2. Legal basis for data processing

The legal basis for the temporary storage of the data and the log files is Art. 6 (1) (f) GDPR. Our legitimate interest arises from the technical necessity of providing a functional website, optimising the website and ensuring the security of our IT systems.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to deliver the website to the user's device. For this purpose, the user's IP address must remain stored for the duration of the session. Storage in log files takes place to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our IT systems. The data is not evaluated for marketing purposes in this context.

4. Storage period

The data is erased as soon as it is no longer required to achieve the purpose for which it was collected. For data collected to provide the website, this is the case when the respective session has ended. For data stored in log files, this is the case after fourteen days at the latest.

5. Right to object and removal

The collection of data to provide the website and the storage of data in log files is essential for operating the website. Consequently, the user has no right to object.

6. Hosting

We host the content of our website with the following provider: Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany. Hetzner is a recipient of your personal data and acts as our processor. This corresponds to our legitimate interest within the meaning of Art. 6 (1) (f) GDPR in not having to maintain a server on our own premises. The server location is Germany. Further information on your rights to object and removal in relation to Hetzner can be found at: https://www.hetzner.com/de/rechtliches/datenschutz. You have the right to object to the processing. Whether the objection is successful is determined by weighing up the interests involved. The data is erased as soon as the purpose of the processing no longer applies. The processing of the data specified in this section is neither required by law nor by contract. The website cannot function without this processing. We have concluded a data processing agreement (DPA) with Hetzner.

V. Contact via contact form and email

1. Description and scope of data processing

We provide a contact form on our website. If you use it, the data you enter is transmitted to us: (1) name, (2) email address, (3) subject (category of the enquiry), (4) message text. The form turns this into an email to our mailbox; we do not keep a separate database of contact enquiries. Before submitting, you confirm that you have read this privacy policy.

Alternatively, you can write to us directly at hello@kosten.org. In this case we process the data transmitted with the email.

The emails are sent and stored via our own mail servers in data centres in Germany. The data is not passed on to third parties unless we are legally obliged to do so.

2. Legal basis and purpose

We process the data solely to handle your enquiry. The legal basis is our legitimate interest in answering enquiries (Art. 6 (1) (f) GDPR); if your enquiry aims at a contract, for example an advertising or listing enquiry, additionally Art. 6 (1) (b) GDPR.

3. Storage period and objection

We delete the data as soon as your matter has been finally resolved, at the latest after three years, unless statutory retention obligations (e.g. for business letters) prevent this. You can object to the storage at any time informally by email to hello@kosten.org; the conversation cannot then be continued.

VIII. Affiliate marketing and partner programmes

1. Description and scope of data processing

We finance this free information service through commissions we receive when users conclude a contract with a partner via our links (affiliate marketing). These links are marked (e.g. with an asterisk * or the note "advertisement"). As long as you do not click, nothing is transmitted to partners. If you click on such a link, your browser opens the address of the respective affiliate network or partner. An identifier that identifies us as the referrer is transmitted, along with technical data such as IP address, time of the click, referrer URL and browser information. The network or partner then usually sets a cookie on its own domain so that a later contract can be attributed to us. In addition, we pass on the path of the page on which the link was clicked (e.g. "finanzen-girokonto") as a so-called SubID. This identifier contains no information about you. From the networks we only receive reports without personal reference (e.g. number of contracts and commissions).

2. Networks and partner programmes used

We work in particular with the following affiliate networks: (a) financeAds GmbH & Co. KG, Karlstraße 9, 90403 Nürnberg, Germany (privacy: https://www.financeads.net/aboutus/datenschutz/); (b) Awin AG, Eichhornstraße 3, 10785 Berlin, Germany (privacy: https://www.awin.com/de/rechtliches). In individual cases we also use the direct partner or referral programmes of individual providers, such as Proton AG (Switzerland) or Hostinger (Lithuania); the click then takes you directly to the provider. The respective networks and providers are themselves responsible for processing after the click; please refer to their privacy notices.

3. Legal basis for data processing

The legal basis for passing on the referrer identifier and the SubID is Art. 6 (1) (f) GDPR. Our legitimate interest lies in financing our free information service. Using these links costs you nothing extra; the commission is paid by the provider.

4. Right to object

You can object to the processing by not clicking on partner links and instead visiting the provider's website directly. You can also block third-party cookies in your browser or delete them after visiting a partner site.

5. Insurance comparison calculators by financeAds GmbH & Co. KG

On our insurance pages you can use comparison calculators from financeAds GmbH & Co. KG, Karlstraße 9, 90403 Nürnberg, Germany. The calculator is not loaded automatically: in its place you first see a placeholder, and only when you click "Load calculator" does your browser embed it as an iframe. Your browser then retrieves content from financeAds servers (comparison.financeads.net, bilder.financeads.net, facdn.financeads.net); in particular your IP address, date and time, the page accessed and browser information are transmitted. financeAds also sets a session cookie (PHPSESSID) that is required for the calculator to work. Your entries in the calculator (e.g. age, deductible) are processed exclusively by financeAds. If you click on a tariff in the calculator, the notes on partner links above also apply.

The legal basis is your consent (Art. 6 (1) (a) GDPR, § 25 (1) TDDDG), which you give by clicking "Load calculator". If you also tick "Always load financeAds calculators", we remember this decision in your browser's local storage and calculators are loaded directly on other pages. You can withdraw this consent at any time with effect for the future by deleting the kosten.org website data in your browser. financeAds is responsible for processing within the calculator; details: https://www.financeads.net/aboutus/datenschutz/. The initial information of financeAds as an insurance broker can be found at https://downloads.financeads.net/comparison/initial_information_de.pdf.

IX. Own anonymous audience measurement, no third-party tracking tools

To improve our service, we measure the use of this website with our own statistics on our server. We record: the page viewed, time, referring site (domain name only, e.g. "google.com"), campaign parameters from the address (utm_source/utm_medium/utm_campaign), window size, position and label of clicked links and buttons (never what you type into form fields), the target domain of clicked external links, how long a page was visible, and whether you returned to us after clicking a partner link. We group page views of the same day using an identifier calculated as a one-way hash from a secret value that changes daily, your IP address shortened by its last segment and your browser identifier (user agent). The IP address and user agent themselves are not stored; the identifier changes every day and cannot be traced back to you. No cookies are set and no information is stored in your browser. The data does not leave our server and is deleted after 365 days. The legal basis is our legitimate interest in analysing and improving our service (Art. 6 (1) (f) GDPR). You can object to this by disabling JavaScript or using a tracking blocker.

On this website, we deliberately do not use tracking tools such as Google Analytics, Google Tag Manager, Meta Pixel (Facebook Pixel), TikTok Pixel or comparable services. No data is transmitted to Google, Meta, TikTok or other third parties for analytics or advertising purposes. We serve fonts, icons, images and scripts exclusively from our own server; no requests are made to Google Fonts or third-party CDNs when you view our pages. The only exception is the financeAds calculator, and only after you click (section VIII.5).

Operators of other websites can embed our calculators or review seals on their pages. If you visit such a page, your browser loads the embedded content from our server; this creates the server log files described in section III, and for embedded calculators the anonymous audience measurement described above records the view. We do not set cookies there either.

X. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. Right of access (Art. 15 GDPR)

You can ask the controller to confirm whether personal data concerning you is being processed by us. If such processing takes place, you can request information from the controller about the following: (a) the purposes for which the personal data is processed; (b) the categories of personal data being processed; (c) the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed; (d) the planned storage period of the personal data concerning you or, if specific information on this is not possible, the criteria for determining the storage period; (e) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to this processing; (f) the existence of a right to lodge a complaint with a supervisory authority; (g) all available information about the source of the data if the personal data was not collected from the data subject; (h) the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved as well as the significance and envisaged consequences of such processing for the data subject. You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you can request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. Right to rectification (Art. 16 GDPR)

You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you is inaccurate or incomplete. The controller must carry out the rectification without undue delay.

3. Right to restriction of processing (Art. 18 GDPR)

You can request the restriction of the processing of personal data concerning you under the following conditions: (a) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data; (b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead; (c) the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims, or (d) if you have objected to the processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds. If the processing of personal data concerning you has been restricted, this data may – apart from its storage – only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a member state. If the processing has been restricted under the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to erasure (Art. 17 GDPR)

a) Obligation to erase: You can request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay if one of the following grounds applies: (1) The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed. (2) You withdraw your consent on which the processing was based pursuant to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and there is no other legal basis for the processing. (3) You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR. (4) The personal data concerning you has been processed unlawfully. (5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union law or the law of the member states to which the controller is subject. (6) The personal data concerning you was collected in relation to the offer of information society services pursuant to Art. 8 (1) GDPR. b) Information to third parties: If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, it shall take reasonable steps, including technical measures, taking into account available technology and the cost of implementation, to inform controllers processing the personal data that you as the data subject have requested the erasure of all links to, or copies or replications of, this personal data. c) Exceptions: The right to erasure does not apply to the extent that processing is necessary (1) for exercising the right of freedom of expression and information; (2) for compliance with a legal obligation which requires processing under Union or member state law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (3) for reasons of public interest in the area of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR; (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or (5) for the establishment, exercise or defence of legal claims.

5. Right to notification (Art. 19 GDPR)

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you has been disclosed, unless this proves impossible or involves disproportionate effort. You have the right vis-à-vis the controller to be informed about these recipients.

6. Right to data portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, provided that (a) the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and (b) the processing is carried out by automated means. In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be adversely affected by this. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. The controller will no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. In connection with the use of information society services – notwithstanding Directive 2002/58/EC – you have the option of exercising your right to object by automated means using technical specifications.

8. Right to withdraw consent under data protection law (Art. 7 (3) GDPR)

You have the right to withdraw your consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The withdrawal can be sent informally by email to hello@kosten.org.

9. Automated individual decision-making, including profiling (Art. 22 GDPR)

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision (a) is necessary for entering into or performing a contract between you and the controller, (b) is authorised by Union or member state law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (c) is based on your explicit consent. We do not use automated decision-making, including profiling.

10. Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

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 personal data concerning you infringes the GDPR. The supervisory authority with which the complaint has been lodged will inform the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR. The supervisory authority responsible for us is: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia), Postfach 20 04 44, 40102 Düsseldorf, Germany, email: poststelle@ldi.nrw.de, website: https://www.ldi.nrw.de

XI. Transfer of personal data to third countries

As a rule, personal data is not transferred to third countries (countries outside the European Union or the European Economic Area). Exceptions are only permitted under the conditions of Art. 44 et seq. GDPR, in particular if there is an adequacy decision by the European Commission, appropriate safeguards such as EU standard contractual clauses have been agreed, or you have given your explicit consent. We ourselves do not use any services that transfer personal data to third countries; in particular, we do not use Google Analytics, Meta Pixel or comparable services from US providers. If you follow a partner link to a provider outside the EU (e.g. Proton AG, Switzerland – the European Commission has issued an adequacy decision for Switzerland), further processing is governed by that provider's privacy notice.

XII. Validity and changes to this privacy policy

This privacy policy is currently valid and dates from November 2026. As our website and the services offered on it develop, or due to changes in legal or regulatory requirements, it may become necessary to amend this privacy policy. You can view and print the current privacy policy at any time on the website at https://kosten.org/datenschutz (English version: https://kosten.org/en/datenschutz).