Privacy notice
Entwurf — Freigabe DT GPR ausstehend: the sections marked like this are a draft that Deutsche Telekom data protection has not approved yet. Everything else describes the processing as the platform implements it today.
This notice explains which personal data the Brand Dialog platform processes, for what purpose, for how long, and what rights you have.
1. Controller and contactEntwurf — Freigabe DT GPR ausstehend (draft)
Deutsche Telekom data protection confirms the responsible unit and the data protection officer's contact.
The controller is Deutsche Telekom AG (Telekom Design and Group Brand Strategy and Marketing Communications), Friedrich-Ebert-Allee 140, 53113 Bonn, Germany.
Questions about the platform: contact@brand-dialog.telekom.com. Data protection questions: Data Protection Officer of Deutsche Telekom AG, Friedrich-Ebert-Allee 140, 53113 Bonn, Germany, datenschutz@telekom.de.
2. What the platform is for
Brand Dialog is Deutsche Telekom's platform for submitting, reviewing and approving marketing and advertising material. National companies, trading partners and agencies upload material; Deutsche Telekom's brand managers check it against the brand strategy and corporate design, approve it, comment on it or return it for revision.
Everyone involved therefore needs to see who submitted a document, who reviewed it and who approved it when. The platform therefore shows the name, company and e-mail address of the users involved.
Other users see a user's business address and phone, mobile and fax numbers only if that user chose "Show my contact details in the user directory" in the settings; then every user with a role above the basic role (contributors, approval managers, managers, administrators) does, regardless of project team. Without that setting only the user themself and the platform's administrators and managers (account management) see them.
The platform does not analyse how you use it: no tracking, no analytics or advertising services, no user profiles.
3. Which data we process
| Data | Purpose | Source |
|---|---|---|
| Account: user ID, login, first and last name, e-mail address, language, roles and permissions, data scopes granted (countries, organisations, brands, regions), account status, time of the last sign-in | sign-in, permissions, attributing your contributions | you, administrators, Microsoft Entra ID (section 5) |
| Business contact data (profile): salutation, title, organisation, user type, country, region, business address, phone, mobile, fax, public e-mail address and phone, display names, profile picture (optional), visibility in the contact directory | collaboration, contact within the project team | you, your account request, administrators |
| Credentials: password (as a hash only), hashes of the last 24 passwords (no reuse), date of the last password change, session and refresh tokens | secure sign-in | you |
| Account request: name, e-mail address, organisation, address, country, user type, optionally phone, mobile, fax, region, contact person | reviewing the request and creating the account | you |
| Project and approval data: projects, documents and versions, comments, annotations in documents, approvals and rejections with person and time, project teams, activities, change history of the records | running and documenting the approval process | you, other users |
| Uploaded files: images, videos, PDF and Office files, previews, and the text and metadata read from them (e.g. author) | review, approval, search | you, other users |
| Shared files: recipient's e-mail address, message, last access | passing on files by link | you |
| Notifications: recipient, name, subject, content and delivery status of every e-mail | informing about project events | the platform |
| Sign-in log: login (for failed attempts the identifier entered), time, result, reason for a failure, IP address; role changes | security, detecting misuse, evidence | the platform |
| Security and server logs: pseudonymous user ID, IP address, time, address requested, result; the sign-in service also logs the browser identifier (user agent) and referring page | operation, security, troubleshooting | the platform |
No special categories of personal data (Art. 9 GDPR) and no payment or bank data are collected.
4. Where the data comes from
You enter most data yourself (account request, profile, uploads, comments, approvals). Data we do not collect from you:
- Microsoft Entra ID (Deutsche Telekom's corporate directory, roles from CAIMAN): for Deutsche Telekom employees, the e-mail address or user principal name, first and last name and the roles assigned.
- Administrators and managers of the platform: creating accounts, roles, data scopes and account status.
- Other users: adding you to project teams; comments, annotations and approvals on your contributions; metadata in files others upload (e.g. author name).
- Previous platform: accounts, projects and documents of the previous Brand Dialog platform were transferred to this platform in 2026.
5. Sign-in and Microsoft Entra ID
External users sign in with e-mail address and password. Passwords are stored as a hash only. After several failed attempts, sign-in to that account is blocked for a while.
Deutsche Telekom employees sign in through Microsoft Entra ID, which passes on the e-mail address or user principal name, first and last name and your roles. Your account is created from these at the first sign-in; roles and data scopes are synchronised at every sign-in.
The sign-in page collects your e-mail address, your IP address and the result of the sign-in (section 6).
6. Logs
Every sign-in and sign-in attempt is stored in the sign-in log with login, time, result and IP address; the platform's administrators and managers can view it. The platform also writes security events (e.g. sign-ins, refused access, exports, role changes) with a pseudonymous user ID, IP address and the address requested to its server logs. The sign-in service logs requests with IP address, address requested, browser identifier and referring page.
The purpose is the security of the platform: detecting attacks and misuse, fixing faults and tracing who had access when. The logs are not used to monitor performance or behaviour, nor for user profiles. You may object to this processing on grounds relating to your particular situation (section 15). Retention: section 14.
8. Third-party content
The pages load no scripts, fonts, images or videos from third parties; all fonts and libraries are served from our server. Links to external offers (e.g. Brand & Design, Content World, CAIMAN) open them only when you click; their privacy notices apply there.
E-mails from the platform contain logos and fonts that your e-mail program loads from brand-dialog.telekom.com when you open them.
9. Uploaded files and document viewer
Every uploaded file is checked for malware before it is stored and converted for preview and search. Text (for images by text recognition) and metadata such as the author are read and stored. Checking, conversion and storage take place only on our server; no external AI or analytics services are used.
PDF documents are shown and annotated with Nutrient Document Engine (made by Nutrient, formerly PSPDFKit). It runs on our server; documents and annotations stay there.
The software regularly checks its licence with the manufacturer's licence server (my.nutrient.io). According to the manufacturer, it also sends anonymous usage analytics over the same connection, which the manufacturer uses to diagnose issues and improve the product; the manufacturer does not publish what they contain. To our knowledge, no documents and no user data are sent; the content of the licence check and the usage analytics is being confirmed with the manufacturer.
10. Who receives your dataEntwurf — Freigabe DT GPR ausstehend (draft)
Deutsche Telekom approves the list of processors with the data processing agreement.
- Other users of the platform: your name, company and e-mail address with submissions, reviews, comments and approvals; your business address and phone numbers only if you agreed to be shown in the user directory (section 2).
- Administrators and managers of the platform (Deutsche Telekom brand managers, support): account management, account requests, sign-in log.
- Upside as Deutsche Telekom's processor: operation, maintenance and development of the platform.
- Hetzner Online GmbH as sub-processor: server and backups in Germany.
- Mailjet (Sinch) as sub-processor: delivery of the platform's e-mails (recipient, name, subject, content).
- Authorities, where we are legally obliged to disclose data.
We do not pass your data on to third parties for their own purposes.
11. Where your data is processed
The platform and its databases run on a server in Hetzner Online GmbH's data centre in Falkenstein, Germany. Backups are stored encrypted on storage of Hetzner Online GmbH.
No transfer of personal data to countries outside the European Union is intended.
12. Test environment with pseudonymised dataEntwurf — Freigabe DT GPR ausstehend (draft)
Deutsche Telekom has to approve the use of pseudonymised production data for testing.
To check new versions before they go live, a copy of the database is transferred every week to a separate test environment on the same server. Before that, login, e-mail address, name and profile picture are replaced by pseudonyms, address, mobile and fax details are deleted, passwords are made unusable and logs are emptied. The data remains pseudonymised personal data; only the people charged with development, testing and operation have access. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a correct and secure platform).
13. Feedback function (test phase)Entwurf — Freigabe DT GPR ausstehend (draft)
Whether the feedback function is offered in production has not been decided yet.
During the test phase, signed-in users can comment on individual pages with a feedback function. It stores login, name, the page including its search parameters, the element commented on and its text, and your comment, on our server. Using it is voluntary.
14. Legal basis and retentionEntwurf — Freigabe DT GPR ausstehend (draft)
Deutsche Telekom data protection sets the legal bases and deletion periods with the deletion concept; automatic deletion after these periods is being implemented.
Legal basis: Art. 6(1)(b) GDPR for your account and the platform's functions; Art. 6(1)(f) GDPR for showing business contact data within the project team, documenting approvals, the logs and the test environment (legitimate interest in traceable and secure collaboration). For Deutsche Telekom employees, the rules on employee data protection apply in addition.
| Data | Retention |
|---|---|
| Account and profile | while the account is in use; accounts without a sign-in for 3 years are deleted after notice |
| Project and approval data, documents | according to Deutsche Telekom's retention rules for approval records; if your account is deleted, your name in them is anonymised |
| Sign-in log (with IP address), security and server logs | 90 days |
| Account requests, unused invitations | until decided, at most 7 days |
| Stored e-mails, change history of account data | 90 days |
| Backups | up to 12 months (daily backups 30 days, weekly 52 weeks), encrypted |
| Test environment | replaced every week |
| Feedback function | until the end of the test phase |
15. Your rightsEntwurf — Freigabe DT GPR ausstehend (draft)
Deutsche Telekom data protection confirms the wording and the competent supervisory authority.
- access to the data processed about you (Art. 15 GDPR)
- rectification of inaccurate or completion of incomplete data (Art. 16 GDPR)
- erasure (Art. 17 GDPR) and restriction of processing (Art. 18 GDPR)
- portability of the data you provided, in a common machine-readable format (Art. 20 GDPR)
- objection to processing based on legitimate interest, on grounds relating to your particular situation (Art. 21(1) GDPR)
- complaint to a supervisory authority, e.g. the State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia (Art. 77 GDPR)
Contact contact@brand-dialog.telekom.com or the data protection officer (datenschutz@telekom.de).
16. Changes to this notice
We update this notice when the processing changes. Every version has a version number and a date (above).