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Comment: wording, grammar


However, there are three exceptions:

  • we excentos (respectively our the network provider) needs to temporarily store the user's IP address in order to defend against cyber-attacks.
    • according to our network provider, the time frame is a maximum of 4 hours and IP addresses are then permanently deleted
    • according to European Court of Justice, also dynamic IP addresses are interpreted as personal data. This question was previously discussed controversely but then finally decided by the European Court.
    • according to our legal advice and interpretation, the temporary storage of IP addresses is acceptable since it complies with a reasoned balance of interests (goal: detect cyber-attacks such as denial-of-service (DOS) attacks which cannot be done without temporarily storing the IP address; the IP addresses are then permanently deleted).
  • if you are using the optional excentos Lead Generator functionality, the Lead Generator component will (depending on your configuration) ask for personal information such as prenamefirst name, lastnamelast name, email address, phone number etc
    • in case you are using the Lead Generator, we excentos also inform informs you that you would have to implement the DOI (Double Opt In) process. Reason is that sending product information to your website visitors can be interpreted as sending out marketing material which requires the explicit confirmation of your website visitor to be owner of the email address before receiving the marketing material. You as a website operator are responsible to check, also in accordance with existing CRM systems and existing DOI information, how to implement that process
  • if you implement questions that ask personal information and provide e.g. free text fields where the user might enter his name
    • example in a gift finder: "who do you want to give a present to?" with a free text box where the user enters "Susan" and the result list shows "OK, here are the gift recommendations for Susan"

Where is an exact description of which data excentos collects and what excentos does with the data?

excentos published a decription description of the data collected on
The background of that formulation is that excentos integrated Product Guides ourselves into our website (e.g. for lead generation and demo purposes), and excentos thus needs to comply with GDPR just in the same way as our customers need to.


Yes, excentos offers a template. Please note - as also mentioned above - that we provide it the template is provided as a service to you but it is not a legally binding document. Please check review it yourselves also in accordance with your website, other services you are using and your local legal requirements if this regulation complies with your legal needs.

The template also includes the possibility for your website visitors to deactivate the data collection in excentos Analytics. In case you want to provide your users with this option, please integrate the below-mentioned iframe iFrame which will then provide a cookie-functionality to disable tracking to excentos Analytics.


As a customer of excentos that integrates excentos Product Guides into your website, you are responsible in terms of DSGVO §4 (7) to comply with data protection regulations. You thus need a DPA (in German: AVV) with excentos.

We excentos thus provide provides standard DPA (in German: AVV) documents: