---
name: gdpr-privacy-notice-eu-oliver-schmidt-prietz-e36fed759514
description: |
  Draft GDPR/DSGVO-compliant privacy notices as .docx for any EU/EEA jurisdiction and audience. Use when user asks to create a privacy policy/notice, mentions "Datenschutzerklärung", "politique de confidentialité", "privacy notice", needs Art. 13/14 disclosures, AI Act transparency, cookie policy, or notices for applicants ("Bewerber-Datenschutz"), employees ("Beschäftigten-Datenschutz"), B2B partners, or B2C customers. Covers DE (DSGVO+BDSG+TDDDG), FR (RGPD+LIL+LCEN), AT, IT, ES, NL, BE, IE, UK GDPR. Five notice types: Website/App, Applicant, Employee, Business Partner, B2C Customer.
metadata:
  author: Oliver Schmidt-Prietz
  license: AGPL-3.0
  version: 2026.02.09
---

# Pan-EU GDPR Privacy Notice Generator

Generate jurisdiction-aware, GDPR-compliant privacy notices as professional .docx documents.

## Workflow Overview

```
1. SCOPE    → Notice type, jurisdiction(s), template choice
2. INTAKE   → Type-driven collection: controller info, data inventory, legal bases
3. DRAFT    → Generate notice from template + type profile + collected info
4. VERIFY   → Art. 13/14 compliance check + type-specific checks + AI Act check
5. DELIVER  → .docx output via docx skill
```

## Step 1: Scope, Notice Type & Template Selection

### Determine Notice Type (FIRST QUESTION)

Before anything else, determine what type of privacy notice is needed. Load `references/NOTICE_TYPES.md` and ask:

> "What type of privacy notice do you need?"

| Type | Description |
|---|---|
| **Website / App** | For visitors, users, subscribers of a website, web app, or mobile app |
| **Applicant / Recruiting** | For job applicants and candidates (Bewerber, candidats) |
| **Employee** | For employees, contractors, interns (Beschäftigte, salariés) |
| **Business Partner (B2B)** | For contact persons at vendors, suppliers, clients, partners |
| **B2C Customer** | For end consumers in a customer/purchase relationship |
| **Combined** | Multiple audiences in one or several linked notices |

The selected type determines:
- Which sections to include/skip in the final document
- Which data categories to probe during intake
- Which legal bases are most likely
- Which type-specific intake questions to ask
- Which retention defaults apply

Refer to `references/NOTICE_TYPES.md` for the full **section map**, **data profile**, **legal bases**, **intake questions**, and **retention defaults** for each type.

### Determine Jurisdiction

Ask which countries/markets the service targets. Load the appropriate reference:

| Target Market | Reference File |
|---|---|
| Germany / DACH | `references/DE.md` |
| France | `references/FR.md` |
| Other EU (AT, IT, ES, NL, BE, IE, UK) | `references/OTHER_EU.md` |
| Always load | `references/EU_COMMON.md` |

For multi-jurisdiction services, load all relevant files and note where requirements differ (e.g., children's age thresholds, DPO thresholds, retention rules).

### Template Selection

Ask the user:

> "I will draft the privacy notice as a professional .docx document. Do you have an existing template or privacy notice I should use as a base? If not, I will use one of our pre-built templates."

| Option | Action |
|---|---|
| User provides template | Use their .docx as base — preserve structure, wording, and formatting; only fill/adapt |
| No user template | Generate from `references/templates.md` using the docx skill |

`references/templates.md` includes: 13-section structure, Art. 21 objection box (visually highlighted), purposes/retention table, cookie table, AI/automated decision-making section, children's data section, proper header/footer with page numbers, A4 formatting, TOC, and full translations for DE, FR, and EN. Select the language matching the target jurisdiction.

**If user provides a template**: faithfully preserve its structure and validated wording. Only replace placeholders and adapt to the specific case. Do NOT rewrite validated legal language.

### Multi-Language Decision Tree

If the service targets multiple jurisdictions or language groups, determine the language approach:

| Scenario | Approach |
|---|---|
| **Single market, single language** | One notice in the market's language (e.g., DE only → German) |
| **Single market, international workforce/users** | Primary language + English version. State which version governs in case of conflict. |
| **Two markets, two languages** | Option A: Two separate notices (one per language), each self-contained. Option B: Bilingual notice with clear visual separation (e.g., side-by-side columns or sequential sections). |
| **Pan-EU / many markets** | English as primary + translations for key markets. Each translation should be a standalone notice, not a partial translation. |
| **Swiss company (nDSG + GDPR)** | Address both the Swiss nFADP (new Federal Act on Data Protection) and GDPR. Typical approach: single notice referencing both regimes, in at least German + French (+ Italian if applicable). Note: nFADP has no consent requirement for general processing but requires information duties similar to Art. 13/14 GDPR. |

**Template handling for bilingual documents**:
- Use the primary-language template as the structural base
- Ensure both language versions contain all mandatory disclosures (a translation gap = a compliance gap)
- Mark the governing language version explicitly (e.g., "In case of discrepancies, the [German/French] version shall prevail.")

**Multi-language verification checklist** (add to Step 4 if applicable):
- [ ] All mandatory Art. 13/14 disclosures present in each language version
- [ ] Governing version clearly identified
- [ ] Legal terminology correctly translated (not machine-translated without review)
- [ ] Supervisory authority information correct for each jurisdiction
- [ ] Jurisdiction-specific requirements addressed in the relevant language version

### Platform Sub-Type (Website/App type only)

If the notice type is **Website / App**, further classify the platform to anticipate data categories. See `references/NOTICE_TYPES.md` → "Website / App" → "Sub-Types & Data Profiles" for details.

| Sub-Type | Typical Additional Data |
|---|---|
| Brochure/corporate site | Contact forms, analytics, cookies only |
| E-commerce | Account, payment, order history, shipping, returns |
| SaaS / Web app | Account, usage data, feature logs, API keys, collaboration data |
| Mobile app | Device ID, push tokens, permissions (camera, location, contacts), app usage |
| Marketplace | Dual roles (buyers/sellers), ratings, messaging, payment escrow |
| Platform with AI features | Training data, AI inputs/outputs, model decisions, profiling |

## Step 2: Information Intake

Collect ALL information before drafting. Use the **type profile** from `references/NOTICE_TYPES.md` to guide the intake — each type pre-defines likely data categories, legal bases, and type-specific questions.

Ask in logical groups, not all at once. Start with Group A (always), then use the type profile to determine which categories to probe and which type-specific questions to ask.

### Group A — Controller Identity
- Company name, legal form, registration number
- Registered address
- Legal representative (name + title)
- Contact email + phone
- DPO appointed? → Contact details (use functional email)

### Group B — Data Inventory
For each collection point (forms, account creation, purchase, cookies, app usage):
- What data is collected?
- Is it mandatory or optional?
- What is the source (direct from user, third party, automated)?

Categories to probe:
- **Identity**: name, email, phone, address, date of birth, photo
- **Account**: credentials, preferences, settings, activity history
- **Technical**: IP, device ID, browser fingerprint, logs
- **Browsing**: pages visited, clicks, session duration, referrer
- **Transaction**: orders, payment method (via provider), invoices
- **Communication**: messages, support tickets, comments
- **Special categories** (Art. 9): health, biometric, political, religious, sexual orientation, ethnic origin, trade union, genetic — **If any Art. 9 data is identified**: consult `EU_COMMON.md` → "Special Category Data (Art. 9)" for the full intake protocol. Determine the Art. 9(2) exception for each category, confirm the dual legal basis (Art. 6 + Art. 9(2)), and document additional safeguards. Common triggers by notice type: Employee (church tax, disability, sick leave, union dues), Applicant (disability, health, religion), B2C (health data for pharmacy/insurance/fitness).
- **AI-related**: inputs to AI systems, AI-generated outputs, automated scores/decisions

### Group C — Purposes & Legal Bases
For each processing activity, determine the legal basis. Reference `EU_COMMON.md` for guidance.

Present as a table for the user to confirm:

| Purpose | Legal Basis | Data Categories |
|---|---|---|
| Service provision / contract execution | Art. 6(1)(b) | [to fill] |
| Account management | Art. 6(1)(b) | [to fill] |
| Legal/tax compliance | Art. 6(1)(c) — [specific law] | [to fill] |
| Analytics | Art. 6(1)(f) or consent | [to fill] |
| Marketing / newsletter | Art. 6(1)(a) consent | [to fill] |
| AI-based processing | [determine per use case] | [to fill] |

### Group D — Recipients & Transfers
- Hosting provider + location
- Payment processor
- Analytics tools
- Email/marketing tools
- CRM / support tools
- AI/ML service providers (e.g., OpenAI, Google AI, Anthropic)
- Any other processors
- Transfers outside EU/EEA → which countries, which mechanism (adequacy, SCCs, DPF, BCRs)

**DPA / Art. 28 Cross-Reference** — For each processor identified:
- Verify a Data Processing Agreement (Art. 28 GDPR) is in place. If not, flag as a **compliance gap** requiring remediation before the notice is finalized.
- **What to disclose in the notice**: processor name (or category), purpose, location, transfer mechanism. Do NOT include DPA terms, sub-processor lists, or TOMs in the privacy notice — these belong in the Art. 28 agreement.
- **What NOT to disclose**: specific technical/organizational measures (Art. 32), sub-processor chains, pricing, SLA details.
- If the user confirms no DPA exists for a processor: note this in the summary and recommend immediate remediation. The privacy notice should still name the processor/category but add a note that the controller is in the process of formalizing the agreement.
- Joint controllership (Art. 26): if applicable, the arrangement's essence must be disclosed in the notice, including respective responsibilities and the contact point for data subjects.

### Group E — Cookies & Tracking
- Cookie categories used (essential, analytics, marketing, social)
- Specific tools (Google Analytics, Meta Pixel, Matomo, HubSpot, etc.)
- CMP solution (Usercentrics, Cookiebot, Axeptio, Didomi, Borlabs, etc.)
- Server-side tracking? Fingerprinting?
- Cookie lifespans

### Group F — AI & Automated Processing
If the service uses AI/ML:
- What AI systems are used and for what purpose?
- Are decisions solely automated or human-in-the-loop?
- Do decisions produce legal or similarly significant effects (Art. 22)?
- Is user data used for model training?
- AI Act classification: prohibited / high-risk / limited-risk / minimal-risk?

### Group G — DPIA Indicators (Art. 35 GDPR)

Check whether a Data Protection Impact Assessment may be required. If **2 or more** of the following indicators apply, inform the user and recommend a DPIA as a separate deliverable:

1. **Systematic evaluation/scoring** of individuals (profiling, credit scoring, performance reviews)
2. **Automated decision-making** with legal or similarly significant effects (Art. 22)
3. **Systematic monitoring** of a publicly accessible area (CCTV, Wi-Fi tracking)
4. **Special category data** or criminal offence data processed at scale (Art. 9/10)
5. **Large-scale processing** of personal data (high volume, broad geographic scope, many data subjects)
6. **Matching or combining datasets** from different sources in ways data subjects would not reasonably expect
7. **Vulnerable data subjects** (employees, children, patients, elderly)
8. **Innovative use of technology** (biometrics, AI/ML, IoT, blockchain for personal data)

**If 2+ indicators are flagged**:
- Inform the user: "Based on the processing activities described, a Data Protection Impact Assessment (DPIA) under Art. 35 GDPR appears to be required."
- Explain the notice implications: the privacy notice should reference that a DPIA has been conducted (without disclosing the DPIA content itself)
- Recommend: "A DPIA is a separate compliance exercise and should be conducted before the processing begins. This privacy notice skill can draft the notice, but the DPIA should be prepared as a standalone document."
- Check national mandatory DPIA lists (DE: DSK-Liste; FR: CNIL list of processing operations requiring DPIA)

### Summary Before Drafting

After collection, produce a structured summary for user confirmation:

```
NOTICE TYPE: [Website / Applicant / Employee / B2B / B2C / Combined]
CONTROLLER: [Name, form, address]
JURISDICTION(S): [Countries]
PLATFORM: [Type / Sub-type if website]
DPO: [Yes/No + contact]
DATA CATEGORIES: [List by collection point]
PURPOSES + BASES: [Table]
PROCESSORS: [List with locations]
TRANSFERS: [Countries + mechanisms]
COOKIES: [Categories + tools + CMP — if applicable per type]
AI PROCESSING: [Yes/No + details]
RETENTION: [Key periods — cross-check with type defaults]
SPECIFICS: [Anything unusual]
SECTIONS TO INCLUDE: [Based on type section map]
SECTIONS TO SKIP: [Based on type section map]
```

Confirm with user before proceeding to draft.

## Step 3: Draft the Notice

### Section Selection by Type

Use the **section map** from `references/NOTICE_TYPES.md` for the selected notice type. Only include sections marked ✅ or ⚠️ (if applicable). Skip sections marked ❌. This avoids irrelevant content (e.g., cookie tables in an applicant notice).

For **combined notices** covering multiple audiences, see `references/NOTICE_TYPES.md` → "Combined Notices" for structural options (single comprehensive, separate, or layered).

### Standard Structure (full — adapt per type)

```
PRIVACY NOTICE / DATENSCHUTZERKLÄRUNG / POLITIQUE DE CONFIDENTIALITÉ
[Company Name]
Last updated: [DATE]

1. WHO WE ARE (Controller identity + DPO)
2. WHAT DATA WE COLLECT (by category, with source + mandatory/optional)
3. WHY WE PROCESS YOUR DATA (purposes + legal bases table, incl. retention per purpose)
4. WHO RECEIVES YOUR DATA (recipients + processors)
5. INTERNATIONAL TRANSFERS (countries + safeguards)
6. HOW LONG WE KEEP YOUR DATA (retention table — can be merged with section 3)
7. YOUR RIGHTS (all applicable rights + exercise procedure)
8. COOKIES & TRACKING (categories + management + CMP reference)
9. AI & AUTOMATED DECISIONS (if applicable — Art. 22 + AI Act)
10. DATA SECURITY (general measures, no sensitive technical details)
11. CHILDREN'S DATA (if applicable — age threshold + mechanism)
12. CHANGES TO THIS NOTICE (notification method)
13. CONTACT (email + postal + form link)
```

### Drafting Rules

- **Language**: Write in the jurisdiction's language. For multi-jurisdiction, primary language first with clear indication of governing version.
- **Tone**: Address the reader as "you"/"Sie"/"vous". Clear, accessible language — understandable by non-lawyers.
- **Art. 21 Right to Object**: Must be presented **prominently and separately** from other rights (GDPR Art. 21(4)). In German notices, a separate "WIDERSPRUCHSRECHT" section is standard practice.
- **Legal bases**: Cite article numbers precisely (e.g., "Art. 6(1)(f) DSGVO" not just "legitimate interest").
- **Retention periods**: Use specific durations with legal justification, not vague language.
- **AI disclosure**: If AI is used, include a dedicated section even if Art. 22 doesn't strictly apply — the AI Act requires transparency.
- **Tables**: Use tables for purposes/bases/retention and for cookie categories. They improve readability.
- **No internal references**: The final document must not contain references to this skill, CNIL guides, or other drafting aids.

## Step 4: Compliance Verification

Before delivery, perform a structured final check in this order:

**1. Re-read the jurisdiction reference(s)** loaded in Step 1 (DE.md, FR.md, OTHER_EU.md). Cross-check:
- Supervisory authority name, address, and URL are correct for the controller's registered seat
- Retention periods match jurisdiction-specific legal citations (not just generic defaults)
- Standard wording blocks (Art. 21 objection, complaint right, controller intro) use the jurisdiction's validated language from the reference file
- Any jurisdiction-specific requirements not yet addressed (e.g., § 26 BDSG for DE employee/applicant, Art. L.34-5 CPCE for FR marketing)

**2. Verify Art. 13/14 mandatory disclosures** against `EU_COMMON.md` → "Mandatory Disclosures Checklist". Every item must be present or explicitly not applicable with reason.

**3. Additional checks:**

- [ ] Art. 21 right to object presented separately and prominently
- [ ] Correct supervisory authority named (check jurisdiction reference)
- [ ] DPO contact included if DPO appointed
- [ ] Cookie section matches actual cookie usage (if included per type)
- [ ] Retention periods are specific (not "as long as necessary" without criteria)
- [ ] Transfer mechanisms match actual processor locations
- [ ] AI/automated decision-making addressed if applicable
- [ ] Children's data addressed if service accessible to minors
- [ ] Special category data (Art. 9): dual legal basis disclosed (Art. 6 + Art. 9(2)), specific exception identified, additional safeguards mentioned
- [ ] Language matches target jurisdiction
- [ ] No placeholder text remaining ([...], ___, TODO)
- [ ] Update date present
- [ ] Sections match the type's section map (no irrelevant sections, no missing required sections)

**4. Type-specific checks** (from `references/NOTICE_TYPES.md`):

**Applicant**: § 26 BDSG referenced (DE)? Talent pool consent separate? Retention ≤ 6 months post-rejection unless consent? Art. 14 used if data from recruiters?

**Employee**: § 26 BDSG as primary basis (DE)? Works council mentioned if relevant? IT monitoring disclosed? Complex retention chain complete?

**B2B**: Art. 14 disclosure if data not from data subject directly? Source of data disclosed? Contact person vs. contracting entity distinction clear?

**B2C Customer**: Soft opt-in conditions met (DE: § 7(3) UWG)? Payment processor disclosed? Loyalty program terms clear? Profiling disclosed if applicable?

**5. AI Act compliance** (if AI features present):
- [ ] Users informed they interact with AI (Art. 50 AI Act)
- [ ] AI-generated content disclosed where applicable
- [ ] High-risk AI: transparency obligations met
- [ ] Link between Art. 22 GDPR rights and AI system disclosed

## Step 5: Deliver as .docx

Generate the final document using the docx generation skill (`/mnt/skills/public/docx/SKILL.md` in Claude.ai Projects, or the `docx-processing-anthropic` skill in Claude Code). If no docx skill is available, generate well-formatted Markdown as fallback.

### Document Formatting Standards

- **Page size**: A4 (standard for EU documents)
- **Font**: Arial or Calibri, 11pt body, headings proportionally larger
- **Margins**: 2.5 cm all sides (EU standard) = 1417 DXA
- **Structure**: Numbered headings (1., 2., 3...), table of contents for documents > 3 pages
- **Tables**: Light borders, header row shaded, readable cell padding
- **Header**: Company name or "Privacy Notice"
- **Footer**: Page numbers, "Last updated: [DATE]"

Read the docx skill instructions before generating the file. Use `docx-js` for new documents. Follow all critical rules from the docx skill (DXA widths, LevelFormat.BULLET for lists, ShadingType.CLEAR for tables, etc.).

### Delivery

Present the .docx file with:
1. Brief confirmation of what was included
2. Any open questions or assumptions made
3. Recommendation for legal review before publication

> **IMPORTANT**: Always recommend that the user has the notice reviewed by qualified legal counsel before publication. This tool assists in drafting — it does not replace legal advice.

### Post-Generation Checklist & Approval Workflow

Present the following checklist to the user to guide their internal review and publication process:

**Legal Review**:
- [ ] Privacy notice reviewed by qualified data protection counsel / DPO
- [ ] All legal bases confirmed as appropriate for the specific processing activities
- [ ] Retention periods verified against current legal requirements
- [ ] Transfer mechanisms confirmed as valid and up-to-date (especially DPF certifications, SCC versions)
- [ ] Art. 9 special category processing: dual legal basis and safeguards reviewed

**Technical Review**:
- [ ] All processors and tools listed are actually in use (no outdated entries)
- [ ] Cookie table matches actual cookies set by the website (audit with browser dev tools)
- [ ] Data flows match the technical architecture (verify with IT/engineering)
- [ ] Contact details (email, postal, DPO) are correct and monitored

**Translation QA** (if multi-language):
- [ ] Each language version reviewed by a native speaker with legal expertise
- [ ] Legal terminology verified (not raw machine translation)
- [ ] All versions contain identical substantive content
- [ ] Governing version clearly marked

**Publication Requirements**:
- [ ] Notice accessible within 2 clicks from any page (DE: BGH requirement)
- [ ] Linked in website footer / app settings / onboarding flow as appropriate
- [ ] Previous version archived with effective date (for audit trail)
- [ ] Cookie banner / CMP updated to reference the current privacy notice
- [ ] Employees / applicants notified of updated notice (if applicable)

**Ongoing Review Triggers** — Recommend the user reviews the notice when:
- New processors or tools are introduced
- New processing purposes are added
- Legal framework changes (new adequacy decisions, court rulings, regulatory guidance)
- Company undergoes a merger, acquisition, or restructuring
- A data breach occurs that reveals undisclosed processing
- At minimum: annual review

## Cross-References

- **Breach response**: If the user also needs breach notification procedures, reference the `breach-sentinel` skill
- **DPIA**: If processing is likely high-risk, recommend a Data Protection Impact Assessment (Art. 35 GDPR) as a separate exercise
- **Cookie policy**: Can be integrated in the privacy notice or a separate document — ask the user's preference

## Writing Style Guide

| Do | Avoid |
|---|---|
| "you" / "your data" / "Sie" / "Ihre Daten" | "the user" / "the data subject" / "der Betroffene" |
| Short, clear sentences | Dense legal paragraphs |
| Specific examples for complex processing | Vague language ("various data", "diverse Daten") |
| Tables for structured information | Walls of text for purposes/retention |
| Precise article references | Generic "in accordance with applicable law" |
| Active voice | Passive constructions where avoidable |
| Plain language with legal precision | Either pure legalese or oversimplified language |


---
Source attribution: luokai0
Original project: https://github.com/luokai0/ai-agent-skills-by-luo-kai/blob/4d2fb89cdfb75f3f6fd3c6c5ec9ad90ea129eb3c/ai-agent-skills/21-external-registries/08-pinkpixel-collection/gdpr-privacy-notice-eu-oliver-schmidt-prietz/SKILL.md
License: AGPL-3.0-only
License information: https://www.gnu.org/licenses/agpl-3.0.html
Original upstream instructions; downloaded from Dave AI.

## Upstream license notice

                    GNU AFFERO GENERAL PUBLIC LICENSE
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 Copyright (C) 2007 Free Software Foundation, Inc. <https://fsf.org/>
 Everyone is permitted to copy and distribute verbatim copies
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  The precise terms and conditions for copying, distribution and
modification follow.

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  "This License" refers to version 3 of the GNU Affero General Public License.

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  Conveying under any other circumstances is permitted solely under
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  3. Protecting Users' Legal Rights From Anti-Circumvention Law.

  No covered work shall be deemed part of an effective technological
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is effected by exercising rights under this License with respect to
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  4. Conveying Verbatim Copies.

  You may convey verbatim copies of the Program's source code as you
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keep intact all notices of the absence of any warranty; and give all
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  A compilation of a covered work with other separate and independent
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  6. Conveying Non-Source Forms.

  You may convey a covered work in object code form under the terms
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  A separable portion of the object code, whose source code is excluded
from the Corresponding Source as a System Library, need not be
included in conveying the object code work.

  A "User Product" is either (1) a "consumer product", which means any
tangible personal property which is normally used for personal, family,
or household purposes, or (2) anything designed or sold for incorporation
into a dwelling.  In determining whether a product is a consumer product,
doubtful cases shall be resolved in favor of coverage.  For a particular
product received by a particular user, "normally used" refers to a
typical or common use of that class of product, regardless of the status
of the particular user or of the way in which the particular user
actually uses, or expects or is expected to use, the product.  A product
is a consumer product regardless of whether the product has substantial
commercial, industrial or non-consumer uses, unless such uses represent
the only significant mode of use of the product.

  "Installation Information" for a User Product means any methods,
procedures, authorization keys, or other information required to install
and execute modified versions of a covered work in that User Product from
a modified version of its Corresponding Source.  The information must
suffice to ensure that the continued functioning of the modified object
code is in no case prevented or interfered with solely because
modification has been made.

  If you convey an object code work under this section in, or with, or
specifically for use in, a User Product, and the conveying occurs as
part of a transaction in which the right of possession and use of the
User Product is transferred to the recipient in perpetuity or for a
fixed term (regardless of how the transaction is characterized), the
Corresponding Source conveyed under this section must be accompanied
by the Installation Information.  But this requirement does not apply
if neither you nor any third party retains the ability to install
modified object code on the User Product (for example, the work has
been installed in ROM).

  The requirement to provide Installation Information does not include a
requirement to continue to provide support service, warranty, or updates
for a work that has been modified or installed by the recipient, or for
the User Product in which it has been modified or installed.  Access to a
network may be denied when the modification itself materially and
adversely affects the operation of the network or violates the rules and
protocols for communication across the network.

  Corresponding Source conveyed, and Installation Information provided,
in accord with this section must be in a format that is publicly
documented (and with an implementation available to the public in
source code form), and must require no special password or key for
unpacking, reading or copying.

  7. Additional Terms.

  "Additional permissions" are terms that supplement the terms of this
License by making exceptions from one or more of its conditions.
Additional permissions that are applicable to the entire Program shall
be treated as though they were included in this License, to the extent
that they are valid under applicable law.  If additional permissions
apply only to part of the Program, that part may be used separately
under those permissions, but the entire Program remains governed by
this License without regard to the additional permissions.

  When you convey a copy of a covered work, you may at your option
remove any additional permissions from that copy, or from any part of
it.  (Additional permissions may be written to require their own
removal in certain cases when you modify the work.)  You may place
additional permissions on material, added by you to a covered work,
for which you have or can give appropriate copyright permission.

  Notwithstanding any other provision of this License, for material you
add to a covered work, you may (if authorized by the copyright holders of
that material) supplement the terms of this License with terms:

    a) Disclaiming warranty or limiting liability differently from the
    terms of sections 15 and 16 of this License; or

    b) Requiring preservation of specified reasonable legal notices or
    author attributions in that material or in the Appropriate Legal
    Notices displayed by works containing it; or

    c) Prohibiting misrepresentation of the origin of that material, or
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  All other non-permissive additional terms are considered "further
restrictions" within the meaning of section 10.  If the Program as you
received it, or any part of it, contains a notice stating that it is
governed by this License along with a term that is a further
restriction, you may remove that term.  If a license document contains
a further restriction but permits relicensing or conveying under this
License, you may add to a covered work material governed by the terms
of that license document, provided that the further restriction does
not survive such relicensing or conveying.

  If you add terms to a covered work in accord with this section, you
must place, in the relevant source files, a statement of the
additional terms that apply to those files, or a notice indicating
where to find the applicable terms.

  Additional terms, permissive or non-permissive, may be stated in the
form of a separately written license, or stated as exceptions;
the above requirements apply either way.

  8. Termination.

  You may not propagate or modify a covered work except as expressly
provided under this License.  Any attempt otherwise to propagate or
modify it is void, and will automatically terminate your rights under
this License (including any patent licenses granted under the third
paragraph of section 11).

  However, if you cease all violation of this License, then your
license from a particular copyright holder is reinstated (a)
provisionally, unless and until the copyright holder explicitly and
finally terminates your license, and (b) permanently, if the copyright
holder fails to notify you of the violation by some reasonable means
prior to 60 days after the cessation.

  Moreover, your license from a particular copyright holder is
reinstated permanently if the copyright holder notifies you of the
violation by some reasonable means, this is the first time you have
received notice of violation of this License (for any work) from that
copyright holder, and you cure the violation prior to 30 days after
your receipt of the notice.

  Termination of your rights under this section does not terminate the
licenses of parties who have received copies or rights from you under
this License.  If your rights have been terminated and not permanently
reinstated, you do not qualify to receive new licenses for the same
material under section 10.

  9. Acceptance Not Required for Having Copies.

  You are not required to accept this License in order to receive or
run a copy of the Program.  Ancillary propagation of a covered work
occurring solely as a consequence of using peer-to-peer transmission
to receive a copy likewise does not require acceptance.  However,
nothing other than this License grants you permission to propagate or
modify any covered work.  These actions infringe copyright if you do
not accept this License.  Therefore, by modifying or propagating a
covered work, you indicate your acceptance of this License to do so.

  10. Automatic Licensing of Downstream Recipients.

  Each time you convey a covered work, the recipient automatically
receives a license from the original licensors, to run, modify and
propagate that work, subject to this License.  You are not responsible
for enforcing compliance by third parties with this License.

  An "entity transaction" is a transaction transferring control of an
organization, or substantially all assets of one, or subdividing an
organization, or merging organizations.  If propagation of a covered
work results from an entity transaction, each party to that
transaction who receives a copy of the work also receives whatever
licenses to the work the party's predecessor in interest had or could
give under the previous paragraph, plus a right to possession of the
Corresponding Source of the work from the predecessor in interest, if
the predecessor has it or can get it with reasonable efforts.

  You may not impose any further restrictions on the exercise of the
rights granted or affirmed under this License.  For example, you may
not impose a license fee, royalty, or other charge for exercise of
rights granted under this License, and you may not initiate litigation
(including a cross-claim or counterclaim in a lawsuit) alleging that
any patent claim is infringed by making, using, selling, offering for
sale, or importing the Program or any portion of it.

  11. Patents.

  A "contributor" is a copyright holder who authorizes use under this
License of the Program or a work on which the Program is based.  The
work thus licensed is called the contributor's "contributor version".

  A contributor's "essential patent claims" are all patent claims
owned or controlled by the contributor, whether already acquired or
hereafter acquired, that would be infringed by some manner, permitted
by this License, of making, using, or selling its contributor version,
but do not include claims that would be infringed only as a
consequence of further modification of the contributor version.  For
purposes of this definition, "control" includes the right to grant
patent sublicenses in a manner consistent with the requirements of
this License.

  Each contributor grants you a non-exclusive, worldwide, royalty-free
patent license under the contributor's essential patent claims, to
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  In the following three paragraphs, a "patent license" is any express
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(such as an express permission to practice a patent or covenant not to
sue for patent infringement).  To "grant" such a patent license to a
party means to make such an agreement or commitment not to enforce a
patent against the party.

  If you convey a covered work, knowingly relying on a patent license,
and the Corresponding Source of the work is not available for anyone
to copy, free of charge and under the terms of this License, through a
publicly available network server or other readily accessible means,
then you must either (1) cause the Corresponding Source to be so
available, or (2) arrange to deprive yourself of the benefit of the
patent license for this particular work, or (3) arrange, in a manner
consistent with the requirements of this License, to extend the patent
license to downstream recipients.  "Knowingly relying" means you have
actual knowledge that, but for the patent license, your conveying the
covered work in a country, or your recipient's use of the covered work
in a country, would infringe one or more identifiable patents in that
country that you have reason to believe are valid.

  If, pursuant to or in connection with a single transaction or
arrangement, you convey, or propagate by procuring conveyance of, a
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receiving the covered work authorizing them to use, propagate, modify
or convey a specific copy of the covered work, then the patent license
you grant is automatically extended to all recipients of the covered
work and works based on it.

  A patent license is "discriminatory" if it does not include within
the scope of its coverage, prohibits the exercise of, or is
conditioned on the non-exercise of one or more of the rights that are
specifically granted under this License.  You may not convey a covered
work if you are a party to an arrangement with a third party that is
in the business of distributing software, under which you make payment
to the third party based on the extent of your activity of conveying
the work, and under which the third party grants, to any of the
parties who would receive the covered work from you, a discriminatory
patent license (a) in connection with copies of the covered work
conveyed by you (or copies made from those copies), or (b) primarily
for and in connection with specific products or compilations that
contain the covered work, unless you entered into that arrangement,
or that patent license was granted, prior to 28 March 2007.

  Nothing in this License shall be construed as excluding or limiting
any implied license or other defenses to infringement that may
otherwise be available to you under applicable patent law.

  12. No Surrender of Others' Freedom.

  If conditions are imposed on you (whether by court order, agreement or
otherwise) that contradict the conditions of this License, they do not
excuse you from the conditions of this License.  If you cannot convey a
covered work so as to satisfy simultaneously your obligations under this
License and any other pertinent obligations, then as a consequence you may
not convey it at all.  For example, if you agree to terms that obligate you
to collect a royalty for further conveying from those to whom you convey
the Program, the only way you could satisfy both those terms and this
License would be to refrain entirely from conveying the Program.

  13. Remote Network Interaction; Use with the GNU General Public License.

  Notwithstanding any other provision of this License, if you modify the
Program, your modified version must prominently offer all users
interacting with it remotely through a computer network (if your version
supports such interaction) an opportunity to receive the Corresponding
Source of your version by providing access to the Corresponding Source
from a network server at no charge, through some standard or customary
means of facilitating copying of software.  This Corresponding Source
shall include the Corresponding Source for any work covered by version 3
of the GNU General Public License that is incorporated pursuant to the
following paragraph.

  Notwithstanding any other provision of this License, you have
permission to link or combine any covered work with a work licensed
under version 3 of the GNU General Public License into a single
combined work, and to convey the resulting work.  The terms of this
License will continue to apply to the part which is the covered work,
but the work with which it is combined will remain governed by version
3 of the GNU General Public License.

  14. Revised Versions of this License.

  The Free Software Foundation may publish revised and/or new versions of
the GNU Affero General Public License from time to time.  Such new versions
will be similar in spirit to the present version, but may differ in detail to
address new problems or concerns.

  Each version is given a distinguishing version number.  If the
Program specifies that a certain numbered version of the GNU Affero General
Public License "or any later version" applies to it, you have the
option of following the terms and conditions either of that numbered
version or of any later version published by the Free Software
Foundation.  If the Program does not specify a version number of the
GNU Affero General Public License, you may choose any version ever published
by the Free Software Foundation.

  If the Program specifies that a proxy can decide which future
versions of the GNU Affero General Public License can be used, that proxy's
public statement of acceptance of a version permanently authorizes you
to choose that version for the Program.

  Later license versions may give you additional or different
permissions.  However, no additional obligations are imposed on any
author or copyright holder as a result of your choosing to follow a
later version.

  15. Disclaimer of Warranty.

  THERE IS NO WARRANTY FOR THE PROGRAM, TO THE EXTENT PERMITTED BY
APPLICABLE LAW.  EXCEPT WHEN OTHERWISE STATED IN WRITING THE COPYRIGHT
HOLDERS AND/OR OTHER PARTIES PROVIDE THE PROGRAM "AS IS" WITHOUT WARRANTY
OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO,
THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR
PURPOSE.  THE ENTIRE RISK AS TO THE QUALITY AND PERFORMANCE OF THE PROGRAM
IS WITH YOU.  SHOULD THE PROGRAM PROVE DEFECTIVE, YOU ASSUME THE COST OF
ALL NECESSARY SERVICING, REPAIR OR CORRECTION.

  16. Limitation of Liability.

  IN NO EVENT UNLESS REQUIRED BY APPLICABLE LAW OR AGREED TO IN WRITING
WILL ANY COPYRIGHT HOLDER, OR ANY OTHER PARTY WHO MODIFIES AND/OR CONVEYS
THE PROGRAM AS PERMITTED ABOVE, BE LIABLE TO YOU FOR DAMAGES, INCLUDING ANY
GENERAL, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES ARISING OUT OF THE
USE OR INABILITY TO USE THE PROGRAM (INCLUDING BUT NOT LIMITED TO LOSS OF
DATA OR DATA BEING RENDERED INACCURATE OR LOSSES SUSTAINED BY YOU OR THIRD
PARTIES OR A FAILURE OF THE PROGRAM TO OPERATE WITH ANY OTHER PROGRAMS),
EVEN IF SUCH HOLDER OR OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF
SUCH DAMAGES.

  17. Interpretation of Sections 15 and 16.

  If the disclaimer of warranty and limitation of liability provided
above cannot be given local legal effect according to their terms,
reviewing courts shall apply local law that most closely approximates
an absolute waiver of all civil liability in connection with the
Program, unless a warranty or assumption of liability accompanies a
copy of the Program in return for a fee.

                     END OF TERMS AND CONDITIONS

            How to Apply These Terms to Your New Programs

  If you develop a new program, and you want it to be of the greatest
possible use to the public, the best way to achieve this is to make it
free software which everyone can redistribute and change under these terms.

  To do so, attach the following notices to the program.  It is safest
to attach them to the start of each source file to most effectively
state the exclusion of warranty; and each file should have at least
the "copyright" line and a pointer to where the full notice is found.

    <one line to give the program's name and a brief idea of what it does.>
    Copyright (C) <year>  <name of author>

    This program is free software: you can redistribute it and/or modify
    it under the terms of the GNU Affero General Public License as published
    by the Free Software Foundation, either version 3 of the License, or
    (at your option) any later version.

    This program is distributed in the hope that it will be useful,
    but WITHOUT ANY WARRANTY; without even the implied warranty of
    MERCHANTABILITY or FITNESS FOR A PARTICULAR PURPOSE.  See the
    GNU Affero General Public License for more details.

    You should have received a copy of the GNU Affero General Public License
    along with this program.  If not, see <https://www.gnu.org/licenses/>.

Also add information on how to contact you by electronic and paper mail.

  If your software can interact with users remotely through a computer
network, you should also make sure that it provides a way for users to
get its source.  For example, if your program is a web application, its
interface could display a "Source" link that leads users to an archive
of the code.  There are many ways you could offer source, and different
solutions will be better for different programs; see section 13 for the
specific requirements.

  You should also get your employer (if you work as a programmer) or school,
if any, to sign a "copyright disclaimer" for the program, if necessary.
For more information on this, and how to apply and follow the GNU AGPL, see
<https://www.gnu.org/licenses/>.


## Additional upstream notices

gdpr-privacy-notice-eu-oliver-schmidt-prietz-e36fed759514/references/NOTICE_TYPES.md

# Privacy Notice Types — Profiles & Guidance

## Table of Contents
1. [Type Selection](#type-selection)
2. [Website / App](#website--app)
3. [Applicant / Recruiting](#applicant--recruiting)
4. [Employee](#employee)
5. [Business Partner (B2B)](#business-partner-b2b)
6. [B2C Customer](#b2c-customer)
7. [Combined Notices](#combined-notices)

---

## Type Selection

Ask the user as the **very first question** after jurisdiction:

> "What type of privacy notice do you need?"

| Type | Typical Trigger Phrases |
|---|---|
| **Website / App** | "website", "app", "online service", "landing page", "SaaS", "platform" |
| **Applicant** | "Bewerber", "applicant", "recruiting", "career page", "candidat", "Bewerbungsverfahren" |
| **Employee** | "Mitarbeiter", "employee", "HR", "salarié", "Beschäftigte", "workforce" |
| **Business Partner** | "B2B", "vendor", "supplier", "business partner", "Geschäftspartner", "partenaire" |
| **B2C Customer** | "customer", "Kunde", "client", "loyalty", "CRM", "retail", "e-commerce" |

If the user needs multiple types → see [Combined Notices](#combined-notices).

Each type profile below defines:
- **Section map**: Which of the 13 standard sections to include, skip, or adapt
- **Likely data categories**: Pre-populated suggestions to accelerate intake
- **Likely legal bases**: Default assumptions to confirm with user
- **Type-specific intake questions**: Additional questions beyond standard Groups A–F
- **Type-specific legal considerations**: Jurisdiction-dependent rules
- **Retention defaults**: Common retention periods for this type

---

## Website / App

### Section Map

| Section | Include? | Notes |
|---|---|---|
| 1. Controller | ✅ Always | |
| 2. Data collected | ✅ Always | Focus on collection points: forms, account, cookies |
| 3. Purposes & bases | ✅ Always | |
| 4. Recipients | ✅ Always | Heavy on tech processors |
| 5. Transfers | ✅ Always | Most web tools involve US transfers |
| 6. Retention | ✅ Always | |
| 7. Rights | ✅ Always | |
| 8. Cookies & tracking | ✅ **Critical** | Core section for this type |
| 9. AI & automated | ✅ If applicable | Chatbots, recommendations, content personalization |
| 10. Security | ✅ Always | |
| 11. Children | ✅ If service accessible to minors | |
| 12. Changes | ✅ Always | |
| 13. Contact | ✅ Always | |

### Sub-Types & Data Profiles

**Brochure / Corporate Site** (minimal data):
- Identity: name, email (contact form only)
- Technical: IP, browser/OS, access logs
- Cookies: analytics, possibly social embeds
- Legal bases: Legitimate interest (analytics, security), consent (marketing cookies)

**E-Commerce**:
- All brochure data PLUS: account data, shipping address, payment (via provider), order history, returns, wishlist
- Legal bases: Contract (orders, account), legal obligation (invoices), consent (newsletter, marketing), legitimate interest (fraud prevention)

**SaaS / Web App**:
- All brochure data PLUS: account, usage/feature logs, API usage, collaboration data, uploaded content, settings
- Legal bases: Contract (service provision), legitimate interest (product improvement, security)

**Mobile App**:
- All web app data PLUS: device ID, push tokens, device permissions (camera, location, microphone, contacts), app usage metrics, crash logs
- Must disclose each permission and its purpose

**Marketplace / Platform**:
- Dual data subjects (buyers + sellers), ratings/reviews, messaging, payment escrow, seller verification documents
- Consider separate sub-sections for each user role

### Type-Specific Intake Questions
1. What forms exist on the site? (contact, registration, checkout, newsletter)
2. Is there user account creation? What data is required vs. optional?
3. What analytics tools are used? (GA4, Matomo, Plausible, Mixpanel)
4. Any third-party embeds? (YouTube, Google Maps, social buttons, chat widgets)
5. Any A/B testing or personalization tools?
6. Does the site use a CDN? (Cloudflare, Fastly — may involve data transfer)
7. Is there a blog with comments?
8. Any user-generated content?

### Retention Defaults
| Data | Duration | Basis |
|---|---|---|
| Contact form submissions | 6–12 months after resolution | Art. 6(1)(f) |
| Active account | Duration of relationship | Art. 6(1)(b) |
| Inactive account | 2–3 years after last activity | Prospecting limitation |
| Server logs | 7–30 days | Art. 6(1)(f) security |
| Cookies | Max 13 months (FR) / session-based or as declared | TDDDG § 25 / CNIL |
| Invoices | 6–10 years depending on jurisdiction | HGB/AO/Code de commerce |

### Sample Clause Patterns

**Analytics consent row** (purposes table):
```
| Web analytics | Understanding how visitors use our website to improve user experience | Art. 6(1)(a) GDPR — your consent via our cookie banner | Anonymized: unlimited; pseudonymized: [13 months / 26 months] |
```

**Third-party embed disclosure**:
```
Our website embeds content from third-party services ([YouTube / Google Maps / social media plugins]). When you access pages containing such content, a connection is established to the provider's servers, which may set cookies and collect your IP address. Legal basis: Art. 6(1)(a) GDPR — your consent. You can manage your preferences via our consent tool at any time.
```

**Soft opt-in clause** (existing customers):
```
If you have previously purchased [goods/services] from us, we may send you information about similar [goods/services] by email. This is based on [§ 7(3) UWG (DE) / Art. L.34-5 CPCE (FR) / Regulation 22 PECR (UK)]. You can unsubscribe at any time using the link in each email or by contacting us.
```

**Newsletter consent**:
```
| Newsletter & marketing emails | Sending you information about [products/services/offers] | Art. 6(1)(a) GDPR — your consent | Until you withdraw your consent |
```

**Contact form**:
```
| Responding to your inquiry | Processing and responding to your contact form submission | Art. 6(1)(f) GDPR — our legitimate interest in responding to inquiries / Art. 6(1)(b) GDPR if related to a contract | 6 months after resolution of your inquiry |
```

---

## Applicant / Recruiting

### Section Map

| Section | Include? | Notes |
|---|---|---|
| 1. Controller | ✅ Always | |
| 2. Data collected | ✅ Always | Sensitive data likely (health, disability, photo) |
| 3. Purposes & bases | ✅ Always | § 26 BDSG central in DE |
| 4. Recipients | ✅ Always | Recruiting platforms, background check providers, group companies |
| 5. Transfers | ✅ If applicable | Cloud HR tools (Workday, SAP SuccessFactors, Greenhouse) |
| 6. Retention | ✅ **Critical** | Short retention after rejection is key compliance point |
| 7. Rights | ✅ Always | |
| 8. Cookies & tracking | ⚠️ Only if career page has own cookies | Often minimal or handled by main site notice |
| 9. AI & automated | ✅ If applicable | CV screening, AI matching, automated pre-selection |
| 10. Security | ✅ Always | Emphasize confidentiality of application |
| 11. Children | ❌ Usually skip | Unless internship programs for minors |
| 12. Changes | ✅ Always | |
| 13. Contact | ✅ Always | |

### Likely Data Categories
- **Identity**: full name, date of birth, nationality, photo (if submitted), gender
- **Contact**: address, email, phone
- **Professional**: CV/resume, cover letter, work history, education, certifications, references
- **Assessment**: interview notes, assessment results, test scores
- **Sensitive (Art. 9)**: disability status (for accommodation / Schwerbehinderung), health (pre-employment medical), sometimes religion (church tax in DE)
- **Technical**: IP/logs if online application portal
- **AI-derived**: matching scores, automated screening results (if applicable)

### Likely Legal Bases
| Purpose | DE | FR | Generic EU |
|---|---|---|---|
| Application processing | § 26 Abs. 1 BDSG | Art. 6(1)(b) pre-contractual | Art. 6(1)(b) |
| Talent pool (future openings) | Consent (§ 26 Abs. 2 BDSG) | Consent Art. 6(1)(a) | Consent |
| Background checks | § 26 Abs. 1 BDSG (if necessary) | Art. 6(1)(b) + proportionality | Art. 6(1)(b) or (f) |
| Disability/Schwerbehinderung | § 26 Abs. 3 BDSG | Art. 9(2)(b) employment law | Art. 9(2)(b) |
| Equal opportunity monitoring | Art. 9(2)(b) employment law | Art. 9(2)(b) | Art. 9(2)(b) |
| AI-based screening | § 26 BDSG + Art. 22 DSGVO | Art. 6(1)(b) + Art. 22 RGPD | Art. 22 GDPR |

### Type-Specific Intake Questions
1. Is there an applicant tracking system (ATS)? Which one? (Personio, Workday, Greenhouse, SAP SF, BambooHR)
2. Do you use AI for CV screening or candidate matching?
3. Do you keep applications in a talent pool for future positions? For how long? With consent?
4. Are background checks or reference checks conducted?
5. Is there a works council (Betriebsrat) involved in the hiring process?
6. Do you collect disability status (Schwerbehinderung)?
7. Are external recruiters or headhunters involved (joint/separate controllership)?
8. Is the career page on the main website or a separate platform?
9. Do you process applicant data within a group of companies?

### Retention Defaults
| Data | Duration | Basis |
|---|---|---|
| Rejected applicant — standard | 6 months after rejection | AGG limitation period (DE), reasonable period (EU) |
| Rejected applicant — extended (with consent) | Up to 24 months | Consent for talent pool |
| Hired → employee | Transfers to employee file | § 26 BDSG / employment relationship |
| Assessment results | Delete with application | Same as application |
| Background check results | Immediately after decision | Data minimization |

### Type-Specific Legal Considerations
- **Germany**: § 26 BDSG is the primary legal basis, NOT Art. 6(1)(b). Art. 88 DSGVO + § 26 BDSG is the specific regime. Works council agreements (Betriebsvereinbarung) may serve as legal basis.
- **France**: CNIL "Guide recrutement" (2023) applies. Photo on CV: cannot be required. Criminal record check: limited to specific roles.
- **AI screening**: Art. 22 DSGVO applies if solely automated decisions with significant effect on the applicant. Must disclose logic, significance, consequences. Human review requirement.

### Sample Clause Patterns

**Talent pool consent**:
```
With your separate consent, we store your application documents in our talent pool to consider you for future suitable positions. Legal basis: Art. 6(1)(a) GDPR — your consent [DE: § 26 Abs. 2 BDSG]. Your data will be retained for [12/24] months. You may withdraw your consent at any time by contacting [contact].
```

**Rejection retention**:
```
If your application is unsuccessful, we retain your application data for [6 months (DE) / up to 2 years (FR)] after notification of the rejection. This serves to protect our legitimate interests in the event of potential legal proceedings (e.g., under the AGG / Code du travail). Legal basis: Art. 6(1)(f) GDPR [DE: § 26 Abs. 1 BDSG]. After this period, your data will be deleted unless you have consented to inclusion in our talent pool.
```

**AI screening disclosure**:
```
We use [system name] to support our candidate selection process. This system [analyses CVs for keyword matching / ranks candidates based on qualifications]. The results are used as one factor among others and are always reviewed by our recruitment team before any decision is made. Legal basis: Art. 6(1)(b) GDPR [DE: § 26 Abs. 1 BDSG]. You have the right to obtain human intervention, express your point of view, and contest the decision.
```

**External recruiter / Art. 14 source**:
```
If your data was provided to us by a recruitment agency or headhunter, the source of your data is [agency name / category: "external recruitment agencies"]. We received the following categories of data: [name, contact details, CV, professional qualifications]. We will inform you of this processing at the latest at the time of first contact.
```

---

## Employee

### Section Map

| Section | Include? | Notes |
|---|---|---|
| 1. Controller | ✅ Always | Employer as controller |
| 2. Data collected | ✅ Always | Very broad — payroll, health, performance, IT monitoring |
| 3. Purposes & bases | ✅ Always | Multiple bases: § 26 BDSG, legal obligation, BV |
| 4. Recipients | ✅ Always | Payroll provider, tax authorities, social insurance, pension, group companies |
| 5. Transfers | ✅ If applicable | Global HR platforms, group companies abroad |
| 6. Retention | ✅ **Critical** | Complex multi-period retention |
| 7. Rights | ✅ Always | Note: some rights limited in employment context |
| 8. Cookies & tracking | ⚠️ Only if intranet/employee tools | IT monitoring section instead |
| 9. AI & automated | ✅ If applicable | Performance scoring, workforce analytics, AI in HR tools |
| 10. Security | ✅ Always | |
| 11. Children | ❌ Skip | Unless apprenticeships (Ausbildung) with minors |
| 12. Changes | ✅ Always | |
| 13. Contact | ✅ Always | |

### Additional Sections (Employee-Specific)
- **IT Monitoring / BYOD**: Internet usage, email monitoring, device management policies
- **Video Surveillance**: § 4 BDSG, works council co-determination
- **GPS / Vehicle Tracking**: If company vehicles are tracked
- **Whistleblowing**: HinSchG (DE) / Loi Sapin II (FR) data processing
- **Works Council Access**: What data is shared with the Betriebsrat

### Likely Data Categories
- **Master data**: name, address, date of birth, tax ID, social insurance number, bank details
- **Contract**: employment contract, position, salary, working hours, start/end dates
- **Payroll**: salary, bonuses, tax class, deductions, benefits
- **Time & attendance**: working hours, overtime, vacation, sick leave
- **Performance**: reviews, goals, training, certifications
- **Health**: sick certificates (AU-Bescheinigungen), occupational health, BEM records
- **IT**: login data, email (if monitored), internet usage logs, access badges
- **Sensitive**: disability (SB status), religion (church tax), trade union membership (if payroll-relevant)

### Retention Defaults (DE)
| Data | Duration | Basis |
|---|---|---|
| Payroll records | 6 years after end of employment | § 257 HGB |
| Tax records | 10 years | § 147 AO |
| Social insurance records | Until age 67 + 6 years | SGB IV |
| Personnel file (general) | 3 years after termination | General limitation §§ 195, 199 BGB |
| Sick certificates | 1 year after end of year | Data minimization |
| BEM records | 3 years after end of BEM | Labor court precedent |
| Works council election records | 5 years | BetrVG |

### Type-Specific Intake Questions
1. What HR/payroll system is used? (Personio, SAP HCM, DATEV, Workday)
2. Is there IT monitoring? (Email, internet, screen monitoring)
3. Is there video surveillance on premises?
4. Are company vehicles tracked (GPS)?
5. BYOD policy? Mobile device management?
6. Works council in place? Relevant Betriebsvereinbarungen?
7. Is the company part of a group? Intra-group data sharing?
8. Whistleblowing channel in place?
9. Occupational health management (BEM)?
10. Any AI in HR processes? (People analytics, performance scoring)

### Sample Clause Patterns

**IT monitoring disclosure**:
```
We monitor the use of company IT systems (email, internet, applications) to ensure IT security, prevent data breaches, and comply with legal obligations. Monitoring is limited to metadata (sender/recipient, timestamps, data volumes) and does not include content surveillance. Legal basis: Art. 6(1)(f) GDPR [DE: § 26 Abs. 1 BDSG]. [If works council agreement exists: Processing is also based on the works council agreement dated [date] pursuant to § 26 Abs. 4 BDSG.]
```

**Church tax clause** (DE):
```
| Church tax processing | Calculating and remitting church tax as legally required | Art. 6(1)(c) GDPR + Art. 9(2)(b) GDPR, § 26 Abs. 3 BDSG, § 51a EStG | Duration of employment + 6 years (§ 257 HGB) |
```

**Sick leave handling**:
```
We process sick leave certificates (AU-Bescheinigungen / arrêts maladie) for the purpose of continued pay entitlement and absence management. We only receive information about the duration of incapacity, not the diagnosis. Legal basis: Art. 6(1)(c) GDPR + Art. 9(2)(b) GDPR [DE: § 26 Abs. 3 BDSG + § 5 EFZG]. Retention: [1 year after end of calendar year (DE) / duration + 5 years (FR)].
```

**BYOD clause**:
```
If you use personal devices for work purposes (BYOD), we process device identifiers and usage data through our mobile device management (MDM) solution [name] to protect company data and ensure IT security. We do not access personal content on your device. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in IT security [DE: § 26 Abs. 1 BDSG].
```

---

## Business Partner (B2B)

### Section Map

| Section | Include? | Notes |
|---|---|---|
| 1. Controller | ✅ Always | |
| 2. Data collected | ✅ Always | Minimal — contact persons, not companies |
| 3. Purposes & bases | ✅ Always | Legitimate interest dominant |
| 4. Recipients | ✅ Always | CRM, ERP, group companies |
| 5. Transfers | ✅ If applicable | CRM/ERP often US-based |
| 6. Retention | ✅ Always | Tied to commercial retention obligations |
| 7. Rights | ✅ Always | |
| 8. Cookies & tracking | ❌ Usually skip | Unless B2B portal with login |
| 9. AI & automated | ⚠️ Rarely | Only if credit scoring or AI in procurement |
| 10. Security | ✅ Always | |
| 11. Children | ❌ Skip | Not applicable |
| 12. Changes | ✅ Always | |
| 13. Contact | ✅ Always | |

### Key Distinction: Art. 13 vs. Art. 14
Business partner notices often involve **Art. 14** (data not collected directly from the data subject):
- Contact persons at a business partner may not have provided their data directly
- Their details may come from the company itself, public registers, LinkedIn, trade fairs
- Art. 14 requires disclosing the **source** of data and **categories** of data
- Must be provided within **1 month** of obtaining the data, or at first communication

### Likely Data Categories
- **Business contact**: name, position/title, business email, business phone, company name
- **Contract**: signatory details, authorized representatives
- **Financial**: company bank details, credit information (for B2B credit checks)
- **Communication**: business correspondence, meeting notes
- **Source**: How the contact was obtained (direct, website, trade fair, public register, referral)

### Likely Legal Bases
| Purpose | Legal Basis | Notes |
|---|---|---|
| Contract management | Art. 6(1)(b) if data subject is the contracting party; Art. 6(1)(f) if contact person at the partner company | Contact persons ≠ contracting entity |
| Pre-contractual measures | Art. 6(1)(b) or (f) | RFQs, proposals, negotiations |
| B2B prospecting | Art. 6(1)(f) | Legitimate interest — balancing test needed |
| Accounting & invoicing | Art. 6(1)(c) — tax/commercial law | HGB, AO, Code de commerce |
| CRM management | Art. 6(1)(f) | Relationship management |
| Compliance / KYC | Art. 6(1)(c) — AML, sanctions | If applicable |
| Credit check | Art. 6(1)(f) or (b) | § 31 BDSG (DE) if scoring |

### Type-Specific Intake Questions
1. How do you obtain business contact data? (Direct, trade fairs, LinkedIn, purchased lists, referrals)
2. Is there a B2B portal or customer login?
3. Do you conduct credit checks on business partners?
4. What CRM/ERP is used? (Salesforce, HubSpot, SAP, Microsoft Dynamics)
5. Do you share data within a corporate group?
6. Any compliance/KYC requirements? (Anti-money laundering, sanctions screening)
7. Are business contacts used for marketing? How (email, phone, events)?

### Retention Defaults
| Data | Duration | Basis |
|---|---|---|
| Active business relationship | Duration of relationship | Art. 6(1)(b)/(f) |
| Post-termination (contracts) | 3 years (general limitation) → up to 10 years (tax) | BGB/HGB/AO |
| Invoices & accounting | 6–10 years | HGB § 257 / AO § 147 |
| Prospecting contacts (no relationship) | 3 years without interaction | LI balancing |
| KYC/AML records | 5 years after end of relationship | GwG § 8 |

### Sample Clause Patterns

**Art. 14 source disclosure**:
```
We may obtain your business contact data from the following sources: your employer or the company you represent, publicly accessible business registers (e.g., Handelsregister, Registre du Commerce), professional networks (e.g., LinkedIn), trade fairs and industry events, or business referrals. Categories of data obtained: name, professional title, business email, business phone, company name.
```

**B2B prospecting legitimate interest**:
```
| Business development / B2B prospecting | Contacting potential business partners about our [products/services] relevant to their professional activity | Art. 6(1)(f) GDPR — our legitimate interest in developing business relationships | 3 years from last interaction |
```

**CRM management**:
```
We store your business contact data in our CRM system ([Salesforce / HubSpot / Microsoft Dynamics]) to manage our business relationship, coordinate communications, and ensure quality of service. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in efficient relationship management.
```

**Credit check clause** (B2B):
```
Before entering into a business relationship, we may obtain creditworthiness information about your company from [Creditreform / SCHUFA / Coface / Euler Hermes]. This includes scoring data and credit ratings. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in assessing credit risk [DE: § 31 BDSG]. You have the right to object to this processing.
```

---

## B2C Customer

### Section Map

| Section | Include? | Notes |
|---|---|---|
| 1. Controller | ✅ Always | |
| 2. Data collected | ✅ Always | Broad — account, purchase, payment, preferences |
| 3. Purposes & bases | ✅ Always | Contract + consent + legitimate interest mix |
| 4. Recipients | ✅ Always | Payment, shipping, marketing tools |
| 5. Transfers | ✅ Always | Payment processors, marketing tools often US-based |
| 6. Retention | ✅ Always | |
| 7. Rights | ✅ Always | Right to object for direct marketing is key |
| 8. Cookies & tracking | ✅ If online | Cross-reference with website notice or integrate |
| 9. AI & automated | ✅ If applicable | Recommendations, scoring, personalization, fraud detection |
| 10. Security | ✅ Always | Payment security particularly relevant |
| 11. Children | ✅ If products/services for minors | Toy stores, gaming, education |
| 12. Changes | ✅ Always | |
| 13. Contact | ✅ Always | |

### Context: Online vs. Offline B2C
This type covers customer relationships that may be purely offline (retail store), purely online (e-commerce — overlaps with Website type), or hybrid. For pure e-commerce, combine this profile with the Website/App profile.

### Likely Data Categories
- **Identity**: name, email, phone, address, date of birth (age verification, birthday offers)
- **Account**: credentials, preferences, wishlist, saved addresses
- **Purchase**: order history, product preferences, returns, warranty claims
- **Payment**: payment method (via processor), billing address, installment data
- **Marketing**: newsletter consent, campaign interactions, promotion usage
- **Loyalty**: points, tier status, program participation
- **Communication**: support tickets, reviews, complaints, chat history
- **Profiling**: purchase patterns, segment assignment, churn prediction, lifetime value

### Likely Legal Bases
| Purpose | Legal Basis | Notes |
|---|---|---|
| Order fulfillment | Art. 6(1)(b) | Contract performance |
| Account management | Art. 6(1)(b) | |
| Payment processing | Art. 6(1)(b) | Via processor (Stripe, PayPal, etc.) |
| Invoice retention | Art. 6(1)(c) | Tax law |
| Newsletter / email marketing | Art. 6(1)(a) consent | Soft opt-in for existing customers (DE: § 7 Abs. 3 UWG; FR: Art. L.34-5 CPCE) |
| Customer profiling | Art. 6(1)(f) or consent | Depends on intrusiveness |
| Fraud prevention | Art. 6(1)(f) | Legitimate interest |
| Product reviews | Art. 6(1)(f) or (b) | |
| Loyalty program | Art. 6(1)(b) if contractual; (a) if optional | |
| Warranty / legal claims | Art. 6(1)(c) or (f) | |

### Type-Specific Intake Questions
1. Is this for online, offline (retail), or omnichannel?
2. What payment methods / processors? (Stripe, PayPal, Klarna, Adyen)
3. Is there a loyalty program? What data is collected for it?
4. Do you do customer profiling or segmentation? How?
5. Email marketing: opt-in or soft opt-in for existing customers?
6. Do you use retargeting (Meta Pixel, Google Ads remarketing)?
7. Product reviews: own system or third-party (Trustpilot, Verified Reviews)?
8. Do you send postal marketing?
9. Customer support channels? (Email, phone, chat, WhatsApp)
10. Any credit check / BNPL (Buy Now Pay Later) integration?

### Retention Defaults
| Data | Duration | Basis |
|---|---|---|
| Active customer account | Duration of relationship | Art. 6(1)(b) |
| Inactive customer (marketing) | 3 years without interaction | LI / CNIL recommendation |
| Order/purchase data | Duration + 3–10 years | BGB/HGB/AO limitation + tax |
| Invoices | 6–10 years | HGB/AO/Code de commerce |
| Payment data | Delete after settlement + chargeback period | PCI DSS + Art. 6(1)(b) |
| Warranty claims | 2 years (legal warranty) | BGB § 438 / Code civil |
| Marketing consent proof | 3–6 years | Proof of consent |
| Reviews | Duration of publication + 3 years | Art. 6(1)(f) |
| Support tickets | 3 years after resolution | Limitation |

### Sample Clause Patterns

**Loyalty program**:
```
If you join our [loyalty program name], we process your purchase history, points balance, tier status, and preferences to administer the program and provide personalized offers. Legal basis: Art. 6(1)(b) GDPR — performance of the loyalty program terms. We may also analyse your purchase patterns to tailor offers to your interests; legal basis: Art. 6(1)(f) GDPR — our legitimate interest in personalized customer communication. You can leave the program at any time by contacting [contact].
```

**BNPL / credit check** (B2C):
```
If you choose to pay by installment ([Klarna / PayPal Pay Later / other BNPL provider]), your data (name, address, date of birth, order details) is transmitted to [provider], which conducts a creditworthiness assessment. [Provider] acts as an independent controller for the credit check. Legal basis for data transmission: Art. 6(1)(b) GDPR — contract performance. For details on [provider]'s processing, see their privacy notice at [URL].
```

**Profiling disclosure**:
```
We analyse your purchase history and browsing behaviour to create a customer profile used for personalised product recommendations and marketing. This profiling does not produce legal or similarly significant effects. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in relevant customer communication. You have the right to object to this profiling at any time (see Section [X] — Your Rights).
```

**Soft opt-in for existing customers**:
```
As an existing customer, we may send you marketing emails about products or services similar to those you have previously purchased. This is based on [§ 7(3) UWG (DE) / Art. L.34-5 CPCE (FR)]. You can opt out at any time by clicking the unsubscribe link in any email or by contacting us at [contact].
```

**Product review clause**:
```
If you submit a product review, we publish your [display name / first name] and review text on our website. Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in providing product information to other customers [or Art. 6(1)(a) if consent-based]. Reviews are retained for the duration of the product listing + 3 years. You can request deletion of your review at any time.
```

---

## Combined Notices

If a user needs a notice covering multiple types (e.g., a company website that also has an applicant portal and B2B partner section):

### Option A: Single Comprehensive Notice (Recommended for Small/Medium)
- Merge all relevant section maps
- Use sub-headings within sections to separate audiences
- Example: Section 3 has sub-sections "3.1 Website visitors", "3.2 Applicants", "3.3 Business partners"
- Risk: document becomes long and hard to navigate

### Option B: Separate Notices (Recommended for Large/Complex)
- One notice per audience / data subject category
- Linked from a central privacy hub page
- Easier to maintain and update
- Better for complex organizations with different processing activities per audience
- German best practice: separate "Datenschutzhinweise für Bewerber" is very common

### Option C: Layered Approach
- One short general notice (1–2 pages) covering common elements (controller, rights, security, contact)
- Separate detailed annexes per type
- Good for organizations with many data subject categories

**Recommendation**: Ask the user which approach they prefer. For most SMEs, Option A with clear sub-headings works. For larger organizations or those with sensitive processing (e.g., employee + applicant), Option B is safer and more maintainable.


# Dave AI resource metadata

Creator / publisher: luokai0
Original project: https://github.com/luokai0/ai-agent-skills-by-luo-kai/blob/4d2fb89cdfb75f3f6fd3c6c5ec9ad90ea129eb3c/ai-agent-skills/21-external-registries/08-pinkpixel-collection/gdpr-privacy-notice-eu-oliver-schmidt-prietz/SKILL.md
Attribution basis: Source repository record

Fields of work: Data & Analytics, Legal, Marketing, Sales
Roles: Business Development, Compliance Officer, Data Analyst, Legal Operations, PR & Communications
Specialties: Word Documents
Tools: Microsoft Word
Country applicability: Belgium, Germany, Spain, France, United Kingdom, Ireland, Italy, Netherlands
Classification basis: Source catalog labels
Instruction SHA-256: 4e731954f934f689be33850a567778bee94e6c55e030bd72671b97a3dfe16d3d