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Data Privacy

Preface

Thank you for your interest in our website. We, COBE GmbH, take the protection of your personal data seriously and would like to inform you at this point about data protection in our company.

Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") in order to ensure the protection of personal data of the person affected by a processing (we also address you as a data subject hereinafter with "customer", "user", "you", or "data subject").

Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (see Articles 13 and 14 GDPR). With this statement (hereinafter: "Privacy Notice"), we inform you about the manner in which your personal data is processed by us.

Our data protection notices have a modular structure. They consist of a general part for any processing of personal data and processing situations that come into play each time a website is called up (A. General) and a special part, the content of which relates in each case only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites as detailed here (B. Visit to websites).

A. General

1. Definitions

Following Art. 4 GDPR, these data protection notices are based on the following definitions:

  • "Personal data" (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or sound recordings may also contain personal data).
  • "Processing" (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e., acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data.
  • "Controller" (Art. 4 No. 7 GDPR) means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • "Processor" (Art. 4 No. 8 GDPR) means a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In terms of data protection law, a processor is in particular not a third party within the meaning of Art. 4 No. 10 GDPR.
  • "Third party” (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or processor, are authorized to process the personal data; this also includes other group-affiliated legal entities.
  • "Consent" (Art. 4 No. 11 GDPR) of the data subject means any freely given, informed and unambiguous expression of will in the form of a statement or other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

2. Name and address of the controller

Responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR is:
‍
COBE GmbH
Hofmannstraße 7B
81379 Munich
Phone: +49 (0)89 997437050
E-mail: infosec@cobeisfresh.com
‍
For further information on our company, please refer to the imprint details on our website https://www.cobeisfresh.com/legal-information.

3. Contact details of the data protection officers

If you have any questions or complaints, please contact one of our data protection officers using the following contact details:
‍
Responsible for COBE GmbH
Jörg F. Smid, DPL Consult, Hohe Bleichen 13, 20354 Hamburg, Germany.
info@dpl-consult.com

Responsible for COBE d.o.o.
Kovačević Prpić Simeunović d.o.o.Trg žrtava fašizma 610 000 Zagreb, Croatia.
+385 1 5576 575
info@kps-law.com

4. Legal basis of data processing

By law, any processing of personal data is in principle prohibited and only permitted if the data processing falls under one of the following justifications:

  • Art. 6 (1) p. 1 lit. a GDPR ("consent"): if the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous confirmatory act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
  • Art. 6 (1) p. 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request;
  • Art. 6 (1) p. 1 lit. c GDPR: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., a legal obligation to keep records);
  • Art. 6 (1) p. 1 lit. d GDPR: If the processing is necessary to protect vital interests of the data subject or another natural person;
  • Art. 6 (1) p. 1 lit. e GDPR: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
  • Art. 6 (1) p. 1 lit. f GDPR ("Legitimate Interests"): If the processing is necessary to protect the legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject override (in particular if the data subject is a minor). 

5. Data deletion and storage period

Your data will only be processed for as long as it is necessary to achieve the processing purposes listed below.

In addition, data may be stored if a (threatened) legal dispute with you or other legal proceedings are pending, or if storage is required due to legal regulations to which we are subject as the controller (e.g. Section 257 HGB, Section 147 AO). These statutory retention periods can be up to 10 years.

6. Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties, taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

7. Recipients of the personal data; Cooperation with processors

We cooperate with our sister company COBE d.o.o., Ulica Hrvatske Republike 33, 31000 Osijek, Croatia. If it is necessary for the processing of your request, we also transfer your personal data to COBE d.o.o.

Like any large company, we also use external service providers in Germany and abroad to process our business transactions (e.g. for IT, logistics, sales and marketing). These service providers act exclusively on our instructions and have been contractually obliged by us to comply with data protection regulations in accordance as per Art. 28 GDPR.

8. Conditions for the transfer of personal data to third countries

As part of our business relationships, your personal data may be transferred to companies outside the European Economic Area (EEA), i.e. in third countries. The European Economic Area consists of the countries of the European Union as well as Norway, Iceland and Liechtenstein. We will inform you about the respective details of the transfer at the relevant points below.

Some third countries are certified by the European Commission as having a level of data protection comparable to the EEA standard through so-called adequacy decisions. When transferring personal data to other third countries, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognized codes of conduct. Please contact our data protection officer (see A.3.) if you would like further information on this.

9. No automated decision making (including profiling)

We do not intend to use any personal data collected from you for any automated decision making process (including profiling).

10. No obligation to provide personal data.

For you as a customer, there is also basically no legal or contractual obligation to provide us with your personal data; however, it may be that we can only provide certain offers to a limited extent or not at all if you do not provide the data required for this, e.g. if you do not provide your contract details on our contact form.

11. Legal obligation to transmit certain data

We may, under certain circumstances, be subject to a specific legal or statutory obligation to provide lawfully processed personal data to third parties, in particular public bodies (Art. 6 (1) p. 1 lit. c GDPR).

12. Your rights

You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details given at the beginning of A. 2. As a data subject, you have the right

  • to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of data, the recipients or categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details. You also have the right to obtain a copy of the personal data that is the subject of the processing;
  • in accordance with Art. 16 GDPR, to demand the correction of incorrect data or the completion of your data stored by us without delay;
  • to demand the deletion of your data stored by us if the requirements of Art. 17 GDPR are met, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
  • in accordance with Art. 18 GDPR, to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful;
  • pursuant to Art. 20 GDPR, to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller ("data portability");
  • to object to the processing in accordance with Art. 21 GDPR, provided that the processing is based on Art. 6 (1) p. 1 lit. e or lit. f GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your objection, we will review the merits of the case and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing. If you object to direct marketing, we will immediately stop processing your personal data for direct marketing purposes;
  • to withdraw your consent at any time in accordance with Art. 7 (3) GDPR. As a result, we may no longer continue the data processing based on this consent in the future. The legality of processing your personal data in the past based on effective consent will not be affected by your withdrawal of consent;
  • to complain to a data protection supervisory authority about the processing of your personal data in our company in accordance with Art. 77 GDPR, e.g. to the data protection supervisory authority responsible for us, the Bavarian State Office for Data Protection Supervision, Promenade 18, 91522 Ansbach.

B. Purpose of processing by visiting our web pages

1. Explanation of function

You can obtain information about our company and the services we offer in particular at https://www.cobeisfresh.com/ together with the associated sub-pages (hereinafter collectively referred to as "websites"). When you visit our websites, personal data may be processed for the purposes explained below.

2. „Log Data”

When you visit our websites, a so-called protocol data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:

  • the URL of the page that requested the page (so-called referrer URL)
  • the name and URL of the requested page
  • the date and time of the request
  • the description of the type, language and version of the web browser used
  • the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
  • the amount of data transferred
  • the operating system
  • the message whether the request was successful (access status/http status code)
  • the GMT time zone difference

3. Contact form data

When contact forms are used, the data transmitted as a result are processed (e.g. surname and first name, telephone number, e-mail address and the time of transmission).

Contact form data is processed for the purpose of handling customer inquiries. The legal basis is Art. 6 (1) lit. b or lit. a GDPR.

4. Applicant data

We process the personal data of applicants for the purpose of carrying out the application process. The legal basis for this processing is Art. 6 para. 1 sentence 1 letter b) GDPR (pre-contractual processing at the request of the data subject). Processing may also be carried out electronically. This is particularly the case if applicants send us the relevant application documents electronically, for example by email. If an employment contract is concluded with an applicant, the transmitted data will be stored for the purpose of fulfilling the employment relationship in compliance with the statutory provisions. If no employment contract is concluded, the application documents will be automatically deleted six months after notification of the rejection decision.

5. Newsletter

In addition to purely informational use of our website, we offer you the opportunity to subscribe to our newsletter, which we use to inform you about current developments in the field of user experience design and software development as well as events. If you subscribe to our newsletter, the following data will be collected, stored and processed by us:

  • the page from which the page was requested (so-called referrer URL)
  • the date and time of the request
  • the description of the type of web browser used
  • the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
  • the e-mail address
  • the date and time of registration and confirmation

We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the e-mails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. For the evaluations, we link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links contained in the newsletter also contain this ID. The data is collected exclusively pseudonymously, i.e. the IDs are not linked with your other personal data, a direct personal reference is excluded.

The newsletter data is processed for the purpose of sending the newsletter. The legal basis for receiving the newsletter is your consent in accordance with Art. 6 para. 1 lit. a GDPR. We use the so-called double opt-in procedure to subscribe to our newsletter. This means that after you have registered, we will send you an email to the email address you have provided in which we ask you to confirm that you wish to receive the newsletter. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data. You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can declare your revocation by clicking on the link contained in every newsletter e-mail or by sending a message to the contact details given in the imprint.

6. Use of cookies, plugins and other services on our website

a) Type, Scope, and Purpose of Data Processing

We use cookies. Cookies are small text files that are assigned to your browser via a unique character string and stored on your hard drive. They transmit specific information back to the server that placed the cookie. Cookies cannot run programs or transfer viruses to your computer, and therefore cannot cause any damage.

Some functions on our website cannot be provided without the use of technically necessary cookies. Other cookies enable us to perform various analyses. For example, some cookies allow us to recognize your browser upon a return visit and transmit different information to us.

We use cookies to make the use of our website more convenient and efficient. For instance, cookies help us analyze your use of our website and recognize your preferred settings (e.g., country and language preferences), allowing us to make our online offerings more user-friendly.

If third parties process information via cookies, they collect the information directly through your browser.

Our website uses different types of cookies and similar technologies (“trackers”). A distinction is made between session cookies, which are deleted when the browser is closed, and permanent cookies, which remain saved beyond the current session.

Our cookies can be categorized according to their function as follows:

  • Necessary
    These trackers are essential to enable processes that are strictly required for providing and delivering a service requested by you. They cannot be deactivated.
  • User Experience
    These trackers enhance your user experience and enable, for example, interactions with external content, networks, and platforms.
  • Performance Measurement
    These trackers measure online traffic and analyze your behavior on our website in an anonymized form in order to continuously optimize our service.
  • Marketing
    These trackers track your user behavior for advertising and marketing purposes. This makes it possible to provide personalized ads or content and to measure their effectiveness.
  • Social Media / External Links
    On our website, you will find links to external providers such as Spotify, Instagram, Apple Podcast, LinkedIn, Medium, Dribbble, Facebook, and GitHub. These links are solely intended to redirect you to the respective providers. Only when you click on a link may personal data be transmitted to the provider. Information on how your data is processed there can be found in the privacy policy of the respective provider.

b) Legal Basis

Cookies that are necessary for the operation of our website and the functions offered therein may be set without your express consent (§ 25 (2) No. 2 of the Telecommunications and Telemedia Data Protection Act – TDDDG). If personal data are processed in this context (e.g., the IP address of your computer), the legal basis for this is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interest).

Cookies that are not technically necessary are only set with your express consent in accordance with § 25 (1) TDDDG in conjunction with Art. 4 No. 11 and Art. 6 (1) sentence 1 lit. a GDPR. These include statistics cookies as well as advertising, targeting, social media, and third-party cookies.

c) Storage Duration

Once the data transmitted to us via cookies is no longer needed for the purposes described above, it will be deleted.

d) Overview of Cookies Used on This Website

A detailed overview of the cookies used on this website — including name, purpose, classification as technically necessary or not, and storage duration — can be found at the following link: Open overview.

e) Configuring Your Browser Settings

Finally, we would like to point out that most web browsers are set by default to accept cookies automatically. However, you can configure your browser settings to allow only certain cookies or to block cookies altogether. Please note that disabling cookies may limit the functionality of our website.

You can also delete previously stored cookies at any time in your browser settings. It is also possible to set your browser to notify you before a cookie is stored.

Since browsers may differ in their structure and functionality, we recommend consulting your browser’s help menu for detailed instructions on configuration.

Please note: If you deactivate cookies, it may be necessary to store a permanent cookie on your device to ensure this preference is saved. If this cookie is later deleted, the deactivation must be repeated.

Editing status of this data protection notice: September 2025