Privacy policy
Introduction
With the following data protection declaration we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) which we process, for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).
The terms used are not gender-specific.
Status: 24. October 2020
Summary of contents
- Introduction
- Responsible
- Overview of the processing operations
- Relevant legal basis
- security measures
- Transmission of personal data
- Processing of data in third countries
- use of cookies
- Business services
- Use of calendar platforms for distribution purposes
- payment service provider
- Provision of the online offer and web hosting
- Newsletters and electronic notifications
- Contests and competitions
- Web analysis, Monitoring and optimisation
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Planning, Organisation and support tools
- Deletion of data
- Amendment and update of privacy policy
- Rights of the data subjects
- Definition of terms
Responsible
Tanja Gauer
Hücheler Ring 57
53773 Hennef
Germany
e-mail address: tanja@tanjagauer.com
Imprint: http://tanjagauer.com/de/impressum/
Overview of the processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Event Data (Facebook) (“Event Data” is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or other means), and that relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc. Event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), login information and contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
- stock data (e.g. names, addresses).
- content data (e.g. entries in online forms).
- contact data (e.g. e-mail, telephone numbers).
- meta/communication data (e.g. device information, IP addresses).
- usage data (e.g. visited websites, interest in content, access times).
- Contract data (e.g. subject matter of contract, duration, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Caterogies of data subjects
- interested parties.
- communication partners.
- customers.
- users (e.g. website visitors, users of online services).
- competition and competition participants.
Purposes of processing
- Providing our online offer and user-friendliness.
- Conversion measurement (measuring the effectiveness of marketing measures).
- Direct marketing (e.g. e-mail or by post).
- Conducting competitions and prize draws.
- Contact enquiries and communication.
- Profiling (creating user profiles).
- Remarketing.
- Range measurement (e.g. (e.g. access statistics, recognition of recurring visitors).
- security measures.
- tracking (e.g. interest/behaviour-related profiling, use of cookies).
- provision of contractual services and customer service.
- Administration and answering of enquiries.
- Office and organisational procedures.
Relevant legal bases
In the following we communicate the legal bases of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal provisions apply in individual cases, we will inform you of these in the data protection declaration.
The data subject has given his consent to the processing of personal data relating to him for one or more specific purposes.
- Consent (Art. 6 para. 1 sentence 1 lit. a. DPA) – The data subject has given his consent to the processing of personal data relating to him for one or more specific purposes.
- Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.
- Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 letter f. DSGVO) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
National data protection regulations in Germany: In addition to the data protection regulations of the Data Protection Basic Regulation, national data protection regulations apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.
These measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, safeguarding of availability and separation of data. Procedures have also been put in place to ensure that data subjects’ rights are respected, that data are deleted and that responses to data breaches are made. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Transmission of personal data
In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if processing takes place in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or transfer required by contract or by law, we process or allow the data to be processed only in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the case of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Our data protection notices may also contain further details on the retention and deletion of data which have priority for the respective processing operations.
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal requirements. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. The purposes for which the cookies are processed by us are explained in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO (further information on objection is provided within the scope of this privacy policy). Users can also declare their objection using the settings of their browser.
Further information on processing processes, procedures and services: - Processing of cookie data based on consent: We use a cookie consent management procedure under which users’ consents to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.
Business services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.
We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Einsatz von Kalender-Plattformen zu Vertriebszwecken
We offer our services on calendar platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms for reach measurement and interest-based marketing.
- Types of data processed: inventory data (e.g. names); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Data subjects: Customers; users (e.g. website visitors, users of online services); business and contractual partners.
- Purposes of processing: provision of contractual services and customer service; marketing; provision of our online offer and user-friendliness.
- Legal grounds: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
Payment service provider
In the context of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the General Terms and Conditions and the data protection information of the payment service providers.
For the payment transactions the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other affected parties’ rights.
- Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: customers, interested parties.
- Provision of contractual services and customer service.
- Legal basis:Fulfilment of contract and pre-contractual enquiries (Art. 6 Par. 1 S. 1 lit. b. DSGVO), legitimate interests (Art. 6 (1) sentence 1 lit. f. DSGVO).
Services and service providers:
- PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); service providers: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Stripe: payment services (technical connection of online payment methods); service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Website: https://stripe.com; Privacy Policy: https://stripe.com/de/privacy.
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.
- Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness; provision of contractual services and customer service.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further information on processing processes, procedures and services: - Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilisation of the servers and their stability; deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident is finally clarified.
- WordPress.com: Hosting platform for blogs / websites; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Order processing agreement: concluded with provider: https://wordpress.com/support/data-processing-agreements/.
Newsletters and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described in the context of a registration for the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other details if these are required for the purposes of the newsletter.
Double-Opt-In procedure: The registration for our newsletter is always done in a so-called Double-Opt-In-Process. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the dispatch service provider are also logged.
Deletion and restriction of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that we have previously given our consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the email address in a block list for this purpose alone (so-called “block list”).
The registration procedure is recorded on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Information on legal bases: The dispatch of the newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law. contents: Information about me, examples of my work, my services, actions and offers.
Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or from the server of the newsletter provider if we use a mailing service provider. Within the framework of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined by means of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be allocated to individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible. In this case, the entire newsletter subscription must be cancelled or objected to.
Condition for the use of free services: Consent to the sending of mailings may be made conditional as a prerequisite for the use of free services (e.g. access to certain contents or participation in certain campaigns). If users wish to take advantage of the free services without registering for the newsletter, please contact us.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: direct marketing (e.g. by e-mail or postal mail), provision of contractual services and customer service.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
- Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Services and service providers:
- Mailchimp: Email sending and email marketing platform; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Order processing contract: https://mailchimp.com/legal/; Standard contractual clauses (ensuring level of data protection for processing in third countries): Inclusion in the order processing contract; Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Contests and competitions
We process personal data of participants in games and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and handling of the game, the participants have consented to the processing or the processing serves our legitimate interests (e.g. the processing of personal data is not necessary for the provision, implementation and handling of the game, the participants have consented to the processing or the processing serves our legitimate interests). e.g. the security of the competition or the protection of our interests against misuse by possible recording of IP addresses when submitting competition entries).
If contributions of the participants are published within the scope of the lottery (e.g. within the scope of a vote or presentation of the lottery contributions or the winners or the reporting on the lottery), we point out that the names of the participants can also be published in this context. The participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the terms of use and data protection regulations of the respective platforms apply additionally. In these cases, we would like to point out that we are responsible for the information provided by the participants in the course of the competition and that any enquiries regarding the competition should be addressed to us.
The participants’ data will be deleted as soon as the competition or contest is finished and the data is no longer required to inform the winners or because further inquiries about the competition can be expected. In principle, the participants’ data will be deleted at the latest 6 months after the end of the competition. Winners’ data may be retained for longer, e.g. in order to be able to answer questions about the prizes or to fulfil the prize services; in this case the retention period depends on the type of prize and is up to three years in the case of items or services, for example, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reports on the competition in online and offline media.
- Processed data types: Inventory data (e.g. names, addresses), content data (e.g. entries in online forms).
- Affected persons: Lottery and competition participants.
- Conducting competitions and prize draws.
- Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO).
Web analysis, monitoring and optimisation
The web analysis (also known as “reach measurement”) serves to evaluate the streams of visitors to our online offering and may include behaviour, interests or demographic information on visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimisation.
In addition to web analysis, we can also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, the content viewed, the web pages visited and the elements used on them, and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymisation by shortening the IP address) to protect the users. In general, the data collected in the course of web analysis, A/B testing and optimisation are not stored as clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Notes on legal bases: If we ask users for their consent to the use of third party providers, the legal basis for processing data is consent. Otherwise, users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles)
- security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Services and service providers:
- Google Analytics:Range measurement and web analysis; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy.
- Google Analytics: web analytics, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of information requests and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further information on processing processes, procedures and services: - Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data);
Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
Plug-ins and embedded functions as and content
We integrate function and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter uniformly referred to as “content”).
The integration always requires that the third party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and the operating system, websites to be referred to, the time of visit and other details on the use of our online offer, as well as being linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third party providers, the legal basis for processing data is consent. Otherwise, users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
Facebook plugins and content: Together with Facebook Ireland Ltd. b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving the ability to identify which content or advertising information is believed to be of interest to users). We have concluded a special agreement with Facebook (“Addendum for Responsible Persons”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of the persons concerned (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the framework of joint responsibility, but on the basis of a contract processing agreement (“Data Processing Conditions “, https://www.facebook.com/legal/terms/dataprocessing) the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the US on the basis of standard contractual clauses (“Facebook-EU Privacy Supplement, https://www.facebook.com/legal/EU_data_transfer_addendum). Users’ rights (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) (“event data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means), and relates to persons or their actions; the data includes Information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as written comments), login information and contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years; the target groups formed from them with the deletion of our Facebook account), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness, provision of contractual services and customer service, security measures, administration and answering enquiries.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).
Services and service providers:
- Facebook plug-ins and content: Facebook social plug-ins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: Ad Settings: https://www.facebook.com/settings?tab=ads.
- YouTube Videos: Video Content; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
Planning, organisation and support tools
We use services, platforms and software of other providers (hereinafter referred to as “third party providers”) for the purposes of organisation, administration, planning and provision of our services. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of third party providers. This may affect various data which we process in accordance with this privacy policy. This data may include in particular master data and contact details of users, data on procedures, contracts, other processes and their contents.
If users are referred to the third party providers or their software or platforms in the course of communication, business or other relations with us, the third party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third party providers.
Notes on legal bases: If we ask users for their consent to the use of third party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre-)contractual services, provided that the use of the third party providers has been agreed in this context. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons concerned: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: contact requests and communication.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), Performance of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Services and service providers:
- WeTransfer:Transfer of files via the Internet; service providers: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; website: https://wetransfer.com; Privacy Policy: https://wetransfer.com/legal/privacy.
Deletion of data
The data processed by us will be deleted in accordance with the law as soon as their consent to processing is revoked or other permissions cease to apply (e.g., if the purpose of the processing of these data has ceased or if they are not necessary for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that are necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.
Amendment and update of the privacy policy
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to act in a cooperative manner (e.g. to give your consent) or to receive other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the DSGVO, which are derived in particular from Art. 15 to 21 DSGVO:
- Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to Art. 6, paragraph 1, letter e or f of the DPA; this also applies to profiling based on these provisions. If personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
- Right of withdrawal in case of consent: You have the right to revoke consents at any time.
- Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and other information and a copy of the data in accordance with the law.
- Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
- Right to deletion and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data relating to you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand restriction of the processing of the data.
- Right to data transferability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the law or to request that it be transferred to another responsible party.
- Complaints to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of suspected infringement, if you consider that the processing of personal data concerning you is in breach of the DPA.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
- IP masking: IP masking is a method of deleting the last octet, i.e. the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, particularly in online marketing
- Conversion measurement: Conversion measurement (also known as “visitor action evaluation”) is a method of determining the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we are able to track whether the ads we have placed on other websites have been successful.
- Personal data: “Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: We speak of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: “Controller” means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: “processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
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