XLS connects partners and enables companies to pay for traditional advertising campaigns and media services with products or services. Given that media budgets are generally always too small and many companies are hampered by stock overhangs that tie up their capital or unutilised production capacities, it makes sense in many cases to capitalise on them by opening up new distribution channels and converting them into additional advertising power.
XLS guides its clients safely through this process, also acting as a partner for media agencies and media marketing companies. All the parties involved should feel comfortable and safe in media bartering. Learn more about media bartering here.
XLS specialises in media bartering and is a market leader in Germany. We see ourselves as an all-rounder for solving different tasks. The two managing directors Klaus A. Westrick and Kai Hesselbach have years of expertise in the industry and have operated on the German market for many years. Since the company was founded in 2000 XLS has developed a distribution system for selling on different products that is flexible and tailored to clients’ individual needs.
Klaus Westrick, who founded the company in 2000, was born in 1966 in Frankfurt am Main, grew up in the Taunus and passed his Abitur exams (A levels) at St. Blasian College in the Black Forest. This was followed by long stints in Madrid, Paris and New York, where Klaus Westrick then completed his broker training.
Until 1995 he worked for well-known banking houses in the securities trading sector before getting into the media industry. From 1996 to 1999 he was the managing director of a bartering company operating according to an American model. By founding XLS, Klaus Westrick decided to adapt this model to suit German market conditions and therefore make it attractive for German firms. Klaus Westrick has three daughters and his interests are motor sport, martial arts, golf and the outdoors.
Kai Hesselbach was born in 1972 and grew up in the Ruhr region. He did his Abitur in 1992 and then studied business administration in Mannheim, majoring in retail management. Since then he has worked for various companies in different sales and marketing roles. His speciality was the automotive and B2B sector.
Kai Hesselbach summarised his expertise in sales and marketing in his book “Gewerbliche Kunden im Blick – Souverän beraten, mehr verkaufen” (“Commercial clients at a glance – expert advice to sell more”), published by Springer Verlag: http://www.springer-automotive-shop.de/shop/buch/verkauf/gewerbliche-kunden-im-blick.html
He is married with two daughters.
Prime Leasing GmbH is used for handling and marketing the vehicles processed each year by the XLS Media Group on a bartering basis. The scope of action ranges from individual leasing contracts through traditional fleets and key account business as well as foreign marketing to the well-established business with major car hire firms. Individual and needs based solutions are the specialty of Prime Leasing GmbH.
Tre Torri Verlag probably has the most expertise in the luxury goods, food and wine segment of all the publishing houses. It has a broad range of content in this field and a highly sought-after image database. As publisher of the highest-quality wine magazine in Europe “FINE”, which can also be seen as a TV show on NTV, it serves an exciting target group at XLS too.
Besides a large number of successful cookbooks such as “Grillen”, “Beef”, “Enie backt”, “Amador”, “Die Kochprofis etc.”, the range includes other blockbusters such as “Maggi” and “Alfred Biolek”. In all, the content segment offers a wealth of exciting bartering opportunities for XLS.
Market research: Permitto knows what makes people tick and can carry out research into subconscious behaviour patterns using what is known as the repertory grid technique. Using completely new approaches, amazing findings can be obtained that would not be possible through conventional polls, even when the group of respondents is very small.
Apart from the ADAC, which uses this tool for its structural and cultural transformation, media agencies employ this tool to acquire new clients by presenting new findings that also have an impact on their overall media strategy – often with high savings potential!
TVSmiles is the first bonus programme that rewards viewers for watching TV. Via the audio signal, the TVSmiles app automatically recognises advertising spots. The app provides its users with exciting opportunities, games and quizzes that match the advertising spots and are about TV and brands. For each interaction users are awarded “Smiles”, the virtual currency of TVSmiles. They can either be redeemed for vouchers from well-known brand shops or exchanged for attractive prizes.
Advertisers who are clients of XLS use TVSmiles to extend their campaigns from TV to mobile, with the result that potential consumers or customers focus more intensively on the brand and the product. Hence, motor vehicle clients of XLS are, for example, able to generate a larger number of test drives.
For 60 years now World Vision has been specifically working to support children in crisis regions the world over. The core concept is “Helping People to Help Themselves”. To achieve lasting improvements, World Vision is involved in regional development cooperation and sponsorships, disaster relief and lobbying for the poor. In acute crisis situations the XLS Media Group provides swift and spontaneous financial support for World Vision.
The children’s cancer charity “Deutsche KinderKrebshilfe” was founded in 1996. It not only works to combat childhood cancers, but also advises and supports those who are affected. Deutsche KinderKrebshilfe raises cash for its activities solely from donations.
It is sad when children’s hopes and prospects of a healthy and long life are destroyed. That is why the XLS Media Group works continually on various projects in this field.
Bartering deals are countertrade transactions. Bartering is the oldest form of trade and, although very few are aware of it, is still practised today between countries and industrial partners on a multi-billion scale.
XLS has developed bartering, which started in the USA and enjoyed tremendous success in Germany and Europe, into an innovative and flourishing business model. XLS has turned media bartering into a business in which advertisers, media agencies and media can participate easily and safely. Thanks to XLS, all the parties involved benefit equally from the advantages of media bartering.
As media bartering is a new concept for many of the parties concerned, it is important to the XLS Media Group that the process is presented simply, transparently and safely and then implemented in that way. For us, the key is that all the parties involved sit down together round a table and support the transaction.
The following 10 steps pave the way for successfully closing a lucrative media bargaining deal.
Joint analysis of requirements with the client: carefully analyse the client’s needs and check whether the potential client, product or desired media service is a sensible and profitable proposition for a barter.
Jointly determine which products, services or unutilised production capacities are to be used, what quantities are up for discussion and what price will be set. This is normally between the cost price and the wholesale price, depending on the quality of the goods. Together, new and alternative distribution channels are identified to prevent the cannibalisation of traditional distribution channels when marketing the goods.
Together with the media agency and the client the fitting selection of media is defined.
The XLS Media Group always tries to match the client’s usual media discount, including, of course, 15 % agency commission. The performance period of the campaign is then laid down together.
The contract outlines the deal transparently, precisely and reliably, yet in a simple way.
The transaction should be uncomplicated and easy to understand – and that also goes for the contract.
Once the contract has been signed the clients or the subsequent buyers are often grateful when the goods are delivered quickly. Once delivery has taken place the outgoing invoice is sent to XLS. XLS generally secures the goods with a bank guarantee prior to delivery.
The campaign is booked and optimised by the client's media agency under the XLS quotas allocated to the media. It is standard practice that the client pays the media agency.
The services are verified through sender protocols and booking confirmations.
XLS invoices the media gross less the agreed discount and the agency commission to the contracting party.
Please note: XLS does not work with virtual currencies such as credits or trade credits.
The net media value is offset against the net value of the client’s goods. The accounts are balanced and the deal is completed successfully.
Goods and services are used to create additional advertising power:
Last, but not least, XLS brings partners together, who generate additional business that, without XLS, would otherwise not have taken place.
XLS enables advertising clients to pay for their media services in full or in part with products or services. It connects all the parties, guides them through the process, provides transparency and security
Using the XLS business model, marketing companies and media owners have the chance to utilise their unused capacities more effectively and generate extra business plus acquire new customers.
The current situation is characterised by stagnating net budgets, with gross advertising space increasing at a huge rate almost daily, especially in the areas of online, mobile, speciality content on demand channels. Brands turn into media.
The surplus media space does not always lead to changed usage, but also to a massive fall in prices.
Using the media bartering tool the XLS Media Group succeeds in procuring additional business, new customers and a higher capacity utilisation for its media partners.
XLS increases the media volumes of its clients by capitalising on goods or other tradeable products and turning them into media volumes. The cooperating media owners receive cash that was not originally envisaged in the media planning and benefit from a higher volume and an improved capacity utilisation. Media companies who implement campaigns jointly with XLS are more productive and increase their turnover through media bartering.
Using the XLS barter tool, agencies have an additional service in their portfolio, with which they can help their customers to convert goods that tie up capital into additional advertising power.
XLS has been working successfully with virtually all the leading media agencies in Germany for years. What agencies find particularly appealing about the cooperation is the opportunity to offer their clients media bartering as a specialised service and the certainty, with XLS, of having a partner for whom long-term business relationships and the benefits for clients are more important than maximising short-term successes, as the goods become an additional currency and payment tool.
The XLS Media Group places great importance on ensuring that its clients feel at ease. Therefore, XLS pays attention to transparency and security, especially as XLS is very interested in a long-term client relationship. In view of the above, it is important for us to get the client’s media agency on board from the outset.
The XLS Media Group generally secures all transactions with bank guarantees. Goods are distributed based on fixed written conditions. The marketing restrictions are contractually fixed.
XLS also has a large number of references from clients, media owners and agencies. XLS guarantees media results, quality and optimum conditions and does not work with notional interim currencies such as credits or trade credits.
The XLS Media Group acquired 1,000 TV sets from Grundig and paid for them with TV advertising space on ProSieben/Sat1. Thus, Grundig sold 1,000 TV sets and had the opportunity to advertise more on TV. Chevrolet in turn purchased the TV sets from the XLS Media Group and paid for them partly in cash and party with motor vehicles. This meant that Chevrolet was able to sell more motor vehicles and acquired the necessary TV sets for its own advertising campaign. Chevrolet communicated this campaign with radio spots and poster advertising - the latter purchased via the XLS Media Group and paid for with additional vehicles. Via Chevrolet’s advertising measures Grundig also achieved additional advertising exposure.
An absolute win-win situation for all concerned.
One category can be more highly discounted (if necessary) through the combined costing of the transaction as a whole (goods and media).
No, the planned or desired sales options are agreed in advance and contractually fixed.
Essentially XLS can supply all media. Availability or pricing options may temporarily restrict the choice.
Most types of media do not have any restrictions or limits in terms of XLS quotas. Some may be subject to limited bookings or a right of postponement.
The invoices for the merchandise are issued by the contracting party to XLS and conversely the invoices for media services rendered are issued by XLS to the contracting party. Transmission confirmations are also provided by media owners. The merchandise and media invoices are offset.
There is no risk for the contracting party, as the media agency is involved beforehand. Goods are only called off once the media service has been supplied or secured beforehand by bank guarantee (no interim currencies). There are a large number of references who can be consulted.
If the advertising spend is too high, it might not be possible to replicate all the discounts or the media requirements are too specialised or fragmented. Some products are less suitable or the sales possibilities are too greatly restricted.
One to four weeks, depending on the complexity.
Your contact details will be treated in accordance with our privacy policy.
Business card: Klaus A. Westrick, Kai Hesselbach
XLS Media Group GmbH
Schöne Aussicht 29
65193 Wiesbaden
Tel.: +49 (0)611 9 00 57-3
Fax: +49 (0)611 9 00 57-55
Managing Director with power of representation:
Klaus A. Westrick, Kai Hesselbach
Registry court: HRB Wiesbaden
Register No.: 12652
VAT ID No. pursuant to Section 27a of the German VAT Law (UStG): DE 220 310 573
Concept & design: Stern GmbH, Wiesbaden.
Disclaimer: Despite diligent checks with regard to content, we do not accept any liability for the contents of external links. The operators of such websites are solely responsible for the content of the linked pages.
Copyright design, layout, text, photos, animations and other contents of this website are protected by copyright. Duplication of the data, information, text, text extracts or photos published here requires the written and express approval of the Prime Medical Trading GmbH & Co. KG.
The following Privacy Policy applies to the use of the website of the xls-group.com (hereafter referred to as „Website“).
We take the protection of personal data very seriously. The collection and processing of your personal data shall always be in line with statutory data-protection regulations, in particular the General Data Protection Regulation (GDPR). We collect and process your personal data to ensure full functionality of our website. The following explanation describes, how, and for what purpose your data is collected and processed and what choices you have in connection with your personal data. By using this website you consent to the collection, use and transmission of your data pursuant to this privacy policy.
1 Name and Address of the controller
Controller for the retrieval, processing and use of personal data in accordance with the General Data Protection Regulation (GDPR) is
XLS Media Group GmbH
Schöne Aussicht 29
65193 Wiesbaden
Telephone: +49 (0)611 9 00 57-3
Telefax: +49 (0)611 9 00 57-55
If a data subject would like to object to a collection, processing or use of all or some of your data based on this Privacy Policy, he or she may send the objection to the above-mentioned controller. The data subject may store or print this Privacy Policy at any time.
2 General use of the webseite
2.1 Access data / Server data
We collect information about all data subjects who use this website. We automatically collect information about the data subject’s user behaviour and interaction with us and we register data regarding their computer or mobile device. We collect, store and use data when a data subject calls up the website. These general data and information are stored in the server log files. Collected may be e.g. the name and URL of the accessed file, the date and time of access to the Internet site, the data volume transmitted, the HTTP response code, the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system reaches our website (referrer), the Internet protocol address (IP address) and the Internet service provider of the accessing system. When using these general data and information, we do not draw any conclusions about the data subject or compile other profiles for the purpose of statistical analysis. They are only used to ensure operation, security and optimisation of our online services, and to anonymously collect information about the number of visitors on the website (traffic) and the volume and type of use of our website and services as well as for billing purposes, i.e. to measure the number of clicks obtained through our cooperation partners. This information allows us to provide personalised and location-specific content and analyse data traffic, trouble-shoot for faults and repair them to improve our services.
We reserve the right to check the log files later, if there is legitimate evidence to suspect an illegal use of the website services.
2.2 Contact options
On our website, we offer data subjects the possibility to contact us via e-mail and/or the contact form. If a data subject uses this service, the information provided will be stored in order to process the request or to answer potential follow-up questions. These data will not be shared with third parties. The collected data will also not be merged with other data, which may have been collected by other components of our website.
2.3 Cookies
On our website we use what is referred to as “cookies” to recognise multiple use of an offer by the same user/owner of an Internet connection. Cookies are small text files, which are stored on the data subjects’ hard drive. They are used to optimise the functionality of our website and our offers. In most cases, they are what is referred to as “session cookies”, which are automatically deleted at the end of each browser session. In some cases, however, these cookies reveal information about data subjects in order for them to be recognised automatically. This recognition is possible because the data subject’s IP address is stored in the cookies. The information we obtain is used to optimise our offer and to make it easier for the data subject to access our website. Data subjects can prevent the setting of cookies by means of a corresponding setting of the Internet browser used, however, an exclusion of cookies may restrict the functionality of our website.
2.4 Use of Google-Analytics with anonymisation function
This website uses Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses cookies, i.e. text files stored on a data subject’s computer, to enable analysis of his or her website use. Information generated by the cookie about his or her use of this website is usually transmitted to a Google server in the United States and stored there.
IP anonymisation
We have activated IP anonymisation on this website. This means that the data subject’s IP address is truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area before their transmission into the United States. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of this website's owner, Google will use this information to evaluate data subjects’ use of the website, compile reports about website activities, and provide the website's operator with further services related to website and Internet use. The IP address sent from the data subject’s browser as part of Google Analytics is not merged with other data by Google.
Browser plug-in
Data subjects can prevent storage of cookies by appropriately setting their browser software; in this case, however, they may not be able to fully use all of the functions offered by this website. In addition, they can prevent data generated by the cookie and relating to their use of the website (including their IP address) from being collected and processed by Google, by downloading and installing a browser plug-in from the following link: tools.google.com/dlpage/gaoptout
Objection to data compilation
Data subjects can click on the following link to prevent any registration by means of Google Analytics. To achieve this, an opt-out cookie will be stored on their device, which will prevent registration of their data on this website in the future: disable Google Analytics For more information regarding the treatment of user data in Google Analytics, please consult the Google Privacy Policy at: support.google.com/analytics/answer/6004245
Contracted data processing
We signed a contract with Google for contract data processing and we meet all of the strict requirements of the German data protection authorities regarding the use of Google Analytics.
Demographic characteristics in Google Analytics
This website uses the demographics feature of Google Analytics. As a result, reports can be produced containing data such as age, gender and interests of the website visitors. This data originates from interest-based advertising from Google and third-party visitor data. This data cannot be assigned to a particular person. Data subjects can deactivate this function at any time in the advert settings of your Google account or by generally prohibiting the compilation of their data by Google Analytics, as is described under the heading “Objection to data compilation“.
2.5 Use of Google Fonts
We incorporated "Google Fonts" provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, in our website. Privacy policy: www.google.com/policies/privacy/, Opt-out: adssettings.google.com/authenticated.
2.6 Use of Vimeo components
We use Vimeo components on our site. Vimeo is a service of Vimeo LCC, 555 West 18th Street, New York, New York 10011, USA. Whenever data subjects visit our website, which is equipped with such a component, this component causes the browser they are using to download a corresponding display of the Vimeo component. When they visit our site and are at the same time logged into Vimeo, Vimeo recognises by means of the information collected by the component, which specific page they are visiting and assigns this information to their personal account at Vimeo. If, for example, they click on the “Play” button or make comments, this information will be conveyed to their personal user account at Vimeo and stored there. In addition, the information that they have visited our site will be passed on to Vimeo. This is done regardless of whether they click on the component/comment or not.
If data subjects want to prevent this transmission and storage of data by Vimeo about their behaviour on our website, they must log out of Vimeo before they visit our site. Vimeo’s Privacy Policy provides more detailed information concerning this, in particular regarding the collection and use of data by Vimeo: vimeo.com/privacy
2.7 SSL encryption
This site uses SSL encryption for security reasons and to protect the transmission of confidential content such as the requests data subjects send to us as site operators. They can identify an encrypted connection by the fact that the browser's address bar changes from "http://" to "https://" as well as by the appearance of the lock icon in your browser address bar. If SSL encryption is enabled, no data you transmit to us can be read by third parties.
2.8 Legal basis and storage duration
The legal basis of the data processing in accordance with the preceding paragraphs is Article 6(1) (f) GDPR. Our interests in data processing include, in particular, ensuring the operation and security of the website, investigating the way the website is used by visitors, and simplifying the use of the website. Unless specifically stated, we store personal data only as long as necessary to fulfill the purposes pursued.
3 Rights of the data subject
Under applicable law, data subjects have various rights regarding their personal information. If you would like to assert these rights, please send your request by e-mail or by mail with a clear identification of your person to the address specified in Point 1. Below is an overview of your rights: 3.1 Right of confirmation and information
You have the right at any time to obtain confirmation from us as to whether personal data relating to you is being processed. If this is the case, you have the right to obtain free information from us about the personal data you have stored together with a copy of this data. Furthermore, there is a right to the following information:
1. the purposes of the processing;
2. the categories of personal data concerned;
3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
6. the existence of the right to lodge a complaint with a supervisory authority;
7. where the personal data are not collected from the data subject, any available information as to their source;
8. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject. If personal data are transmitted to a third country or to an international organisation, data subjects have the right to be informed of the appropriate safeguards under Article 46 of the GDPR in connection with the transfer.
3.2 Right to rectification
Each data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
3.3 Right to erasure (Right to be forgotten)
Each data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
2. The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
3. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
4. The personal data have been unlawfully processed.
5. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
6. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR. Where we have made personal data public and are obliged pursuant to Article 17(1) to erase the personal data, we, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data.
3.4 Right of restriction of processing
Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data,
2. The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
3. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims, or
4. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
3.5 Right to data portability
Each data subject shall have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as
1. the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR and
2. the processing is carried out by automated means.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible.
3.6 Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection, unless it can be demonstrated that there are compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If we processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to our processing of personal data for direct marketing purposes, we will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to our processing of personal data concerning him or her by for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
3.7 Automated individual decision-making, including profiling
Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or otherwise significantly affects him or her.
3.8 Right to withdraw data protection consent
Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time.
3.9 Right to complain to a supervisory authority
Each data subject shall have the right to complain to a supervisory authority, in particular in the Member State of his or her residence, employment or the place of the alleged breach, if he or she considers the processing of his or her personal data is unlawful.
4 Data security
We make every effort to ensure the security of data subjects’ data within the framework of applicable data protection laws and technical possibilities. We ensure data subjects’ personal data are encrypted before transmission. This site uses SSL encryption (Secure Socket Layer). However, we point out that there could be security gaps in data communication (e.g. e-mail communication) in the Internet. To safeguard your data, we maintain technical and organisational security measures that we always adapt to state-of-the-art technology. We also do not warrant that our offer will be available at specific times; Disturbances, interruptions or failures can not be excluded. The servers we use are regularly backed up carefully.
5 Existence of automated decision-making
As a responsible company, we do not use automatic decision-making based on personal data collected.
6 Disclosure of data to third parties, no data transfer to non-EU countries
Basically, we only use data subjects’ personal data within our company. If and to the extent that we engage third parties in the performance of contracts (such as logistics service providers), these personal data will only be received to the extent that the transmission is required for the corresponding service. In the event that we outsource certain parts of the data processing ("order processing"), we contractually obligate processors to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the data subject's rights. Data transmission to agencies or persons outside the EU apart of the cases mentioned in this declaration in point 2.4, 2.5, 2.6 does not take place and is not planned.