Privacy policy of Fulmento

Status: 09.05.2020

The following data protection provisions apply to the online offer at If you wish to read or print the entire document in context, please click here.

Responsible body
Responsible office is 4elements Service and Management GmbH, Högerdamm 41, 20097 Hamburg, Telephone: 040 / 30 38 32 5-50, e-mail:, hereinafter “fulmento” or “we” or “us”.

Collection, processing and use of personal data

General information

Personal data is any information relating to an identified or identifiable natural person (e.g. name, address, telephone number, date of birth or e-mail address).
In principle, you can use our online offer without providing personal data. However, the use of certain services may require you to provide personal data, e.g. registration or participation in a competition. Mandatory information is regularly marked with an *.

Processing purposes
We process your personal data for the following purposes:
– Provision of this online offer (legal basis: fulfilment of contract)
– Processing of contact requests (legal basis: fulfilment of contract)

Transfer of data to third parties; service providers
Transfer of data to third parties
Your personal data will only be passed on to third parties by us if this is necessary for the fulfilment of the contract, if we or the third party have a legitimate interest in passing on the data or if we have your consent to do so. If data is transferred to third parties on the basis of a legitimate interest, this is explained in these data protection provisions.
In addition, data may be transferred to third parties if we should be obliged to do so by law or by an enforceable official or court order.

Service provider
We reserve the right to use service providers for the collection or processing of data. Service providers will only receive the personal data from us that they need for their specific activities. For example, your e-mail address may be passed on to a service provider so that they can deliver a newsletter you have ordered. Service providers may also be commissioned to provide server capacity. Service providers are usually integrated as so-called order processors, who may only process the personal data of the users of this online offer according to our instructions.

Disclosure of data in non-EEA countries
In cases where personal data are transferred to countries that do not offer the same level of protection as within the European Union and you have not expressly consented to the transfer of your data to these countries with your consent, we ensure that certain contractual obligations are met The applicable data protection law (including the implementation of the standard contractual clauses of the European Union approved by the European Commission or the EU-US Privacy Shield) must be agreed with each service provider, unless we can rely on other legal bases for the transfer of personal data.

Duration of storage; retention periods
We store your data for as long as this is necessary to provide our online offer and the associated services or we have a legitimate interest in further storage. In all other cases, we delete your personal data with the exception of those data which we must continue to keep in order to fulfil contractual or legal (e.g. tax or commercial law) retention periods (e.g. invoices). Contractual retention periods may also result from contracts with third parties (e.g. holders of copyrights and ancillary copyrights).
We block data that is subject to a retention period until the expiry of the period.

Log files

Whenever you use the Internet, your Internet browser automatically transmits certain information and we store it in so-called log files.
The log files are stored by us for 7 to 10 days for the sole purpose of determining malfunctions and security reasons (e.g. to clarify attempted attacks) and then deleted. Log files whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified and may be passed on to investigating authorities in individual cases.

The following information in particular is stored in the log files:
– IP address (Internet Protocol address) of the terminal device from which the online offer is accessed;
– Internet address of the website from which the online service was accessed (so-called origin or referrer URL);
– Name of the service provider via which the online service is accessed;
– Name of the files or information called up;
– date and time and duration of the access;
– amount of data transferred;
– Operating system and information on the Internet browser used, including installed add-ons (e.g. for the Flash Player);
– http status code (e.g. “request successful” or “requested file not found”).

Cookies and other tracking technologies

What are cookies?
Cookies are small text files that are sent when a website is visited and stored in the user’s browser. If the corresponding website is called up again, the user’s browser sends the contents of the cookies back and thus enables the user to be recognised. Certain cookies are automatically deleted at the end of the browser session (so-called session cookies), others are stored in the user’s browser for a specified time or permanently and then delete themselves automatically (so-called temporary or permanent cookies).

What data is stored in the cookies?
In principle, no personal data is stored in cookies, only an online identification.

How can you prevent the use of cookies or delete cookies?
You can deactivate the storage of cookies via your browser settings and delete already stored cookies in your browser at any time (see technical notes). Please note, however, that without cookies this online service may not function at all or only to a limited extent.
Please also note that objections to the creation of user profiles can sometimes be made using a so-called “opt-out cookie”. If you delete all cookies, an objection may therefore no longer be considered and must be raised again by you.

What kind of cookies do we use?

Absolutely necessary cookies
Certain cookies are required in order for us to provide our online services securely. This category includes for example
– Cookies that serve to identify or authenticate our users;
– Cookies that temporarily store certain user inputs (e.g. contents of a shopping cart or an online form);
– Cookies that store certain user preferences (e.g. search or language settings);

Analysis cookies
We use analysis cookies in order to record and statistically evaluate the usage behaviour (e.g. clicked advertising banners, visited subpages, search queries) of our users.

Web analysis

We require statistical information about the use of our online offer in order to make it more user-friendly, to measure reach and to conduct market research.
For this purpose we use the following web analysis tools. The usage profiles created by the tools using analysis cookies or by evaluating the log files are not combined with personal data.
The providers of the tools process data only as processors in accordance with our instructions and not for their own purposes.
The tools either do not use IP addresses of users at all or shorten them immediately after collection.
For each tool you will find information on the respective provider and on how you can object to the collection and processing of data by the tool.
For tools that work with opt-out cookies, please note that the opt-out function is device- or browser-related and is only valid for the device or browser currently in use. If you use several devices or browsers, you must set the opt-out on each individual device and in each browser used.
In addition, you can also prevent the creation of user profiles altogether by deactivating the use of cookies in general.

Google Analytics

Google Analytics is provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). We use Google Analytics with the additional function offered by Google to make IP addresses anonymous: Here, the IP address of Google is usually already shortened within the EU and only in exceptional cases only in the USA and in any case only stored in shortened form.
You can object to the collection or analysis of your data by this tool by downloading and installing the browser plugin available here.

Rights of users

Rights of data subjects
They have a right of access and, under certain conditions, the right to rectification, erasure, limitation of processing or opposition to the processing of their personal data, as well as the right to data transferability.
You may also object at any time to the processing of your personal data for commercial purposes (“objection to commercial processing”). Please note that for organisational reasons there may be an overlap between your revocation and the use of your data in the context of an ongoing campaign.
If you have given us permission to process your data, you can revoke this permission at any time with effect for the future. The legality of the processing of your data until revocation remains unaffected.
To assert your rights, please use the information under contact. Please make sure that we can clearly identify you.

Right of appeal to the supervisory authority
You have the right to lodge a complaint with a data protection authority. You can contact the data protection authority responsible for your place of residence or your federal state or the data protection authority responsible for us.
This is:
Der Hamburgische  Beauftragte für Datenschutz und Informationsfreiheit
Ludwig-Erhard-Straße 22
20459 Hamburg

For information and suggestions on the subject of data protection, we or our data protection officer will be pleased to be at your disposal at the e-mail

If you wish to contact us, you can reach us as follows:
4e software solution GmbH, Högerdamm 41, 20097 Hamburg,
Phone: 040 / 30 38 32 5-50, e-mail: info[at]
Our data protection officer is Dr. Stefanie Wegener.
She can be reached as follows:

Appendix: Technical notes

Internet Explorer:
Instructions here
Mozilla Firefox:
Instructions here
Google Chrome:
Instructions here
Instructions here