Preamble
With the following data protection declaration, we would like to inform you about the types of your data that we process, for what purposes, and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
Responsible
Relevant legal bases
Relevant legal bases according to the GDPR: The following is an overview of the legal basis of the GDPR based on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 (1) p. 1 lit. a) DSGVO) – The data subject has consented to process personal data relating to them for specific purposes.
- Contract performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
- Legal obligation (Art. 6 (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 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require personal data protection.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act 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 erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Processing overview
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Payment details.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Event Data (Facebook).
Special categories of data
- Health data.
- Data on sex life or sexual orientation.
- Religious or ideological beliefs.
- Data showing racial and ethnic origin.
Categories of affected persons
- Customers.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Sweepstakes and Contest Entrants.
- Members.
- Business and Contractual Partners.
- Pupils/ Students/ Participants.
- Participants.
- Persons depicted.
Processing purposes
- Provision of contractual services and customer service.
- Contact requests and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Target group formation.
- Managing and responding to inquiries.
- Conducting sweepstakes and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offer and user-friendliness.
- Information Technology Infrastructure.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk per 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.
The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data and the access, input, transfer, protection of availability, and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
IP address shortening: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not required, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.
TLS encryption (HTTPS): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that protect your data with the recipients of your data.
International data transfers
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 the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer (see Art. 49 GDPR), we only process or leave the data in third countries with a recognized level of data protection (Art. 45 GDPR), in the presence of and compliance with the contractual obligation by so-called standard protection clauses of the EU Commission (Art. 46 GDPR) or in the presence of certifications or binding internal data protection rules (see Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Trans-Atlantic Data Privacy Framework (TADPF): Under the so-called “Data Privacy Framework” (DPF), the level of data protection in the EU has also been recognized for certain companies from the USA. The list of certified companies as well as further information on the DPF can be found on the website of the U.S. Department of Commerce at https://www.dataprivacyframework.gov/. Information in German and other languages can be found on the website of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_de We also inform you about the companies we use that are certified under the Data Privacy Framework.
Data deletion
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 of 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 will be limited to these purposes. That is, 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 defense of legal claims or for the protection of the rights of another natural or legal person.
As part of our privacy notices, we may provide users with additional information regarding the deletion as well as the retention of data that is specific to each processing operation.
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right of revocation for consents: You have the right to revoke any consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request the restriction of the processing of the data in accordance with the law.
- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common, and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another responsible party.
- Complaint to a supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Cookies use
Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed, or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security, and convenience of online offers as well as the creation of analyses of visitor flows.
Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the service (i.e., our online offering) expressly requested by users. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer, load balancing, security, storage of users’ preferences and choices, or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and contain information regarding 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 with the help of 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 fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: In terms of 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 app).
- 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 for reach measurement. 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 the storage period can be up to two years.
General information on revocation and objection (so-called “opt-out”): Users can revoke the consents they have given at any time and object to processing in accordance with the legal requirements. For this purpose, users can, among other things, restrict the use of cookies in the settings of their browser (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures, and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query 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 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. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system, and end device used, legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (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 inquiries.
We process this data in order to fulfill 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. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. 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 fulfill legal obligations. Contractual partners will be informed about further 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 special marking (e.g. colors) 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., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the recording was made or the other documents were created.
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.
- Types of data processed: inventory data (e.g. names, addresses); 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Special categories of personal data: Health data (Art. 9(1) DGSVO); Data concerning sex life or sexual orientation (Art. 9(1) DGSVO); Religious or philosophical beliefs (Art. 9(1) DGSVO); Data revealing racial or ethnic origin (Art. 9(1) DGSVO).
- Affected persons: Customers; prospective customers; business and contractual partners; pupils/ students/ participants.
- Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; management and response to requests.
- Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information needed for delivery, or provision and billing, as well as contact information in order to be able to consult; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Education and Training Services: We process the data of participants in our education and training services (uniformly referred to as “trainees”) in order to provide them with our training services. The data processed in this context, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. In the course of our activities, we may also process special categories of data, in particular information on the health of trainees and students, as well as data revealing ethnic origin, political opinions, religious or ideological beliefs. For this purpose, we obtain the express consent of the trainees, if required, and otherwise process the special categories of data only if it is necessary for the provision of the training services, for purposes of preventive health care, social protection or the protection of vital interests of the trainees; legal bases: contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO).
- Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The data processed, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.In the course of our activities, we may also process special categories of data, here in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. For this purpose, we obtain explicit consent from clients, if required, and otherwise process the special categories of data if this serves the health of clients, the data is public or other legal permissions exist.If it is necessary for our contract performance, for the protection of vital interests or required by law or we disclose or transfer client data to third parties or agents, such as public authorities, billing offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. we disclose or transfer client data to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the requirements of professional law; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Business consulting: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship. a consent of the customers is available, we disclose or transmit the data of the customers in compliance with the requirements of professional law to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Events: We process the data of the participants of the events offered or organized by us, events and similar activities (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to take advantage of the services or promotions associated with participation. If we process health-related data, religious, political or other special categories of data in this context, then this is done within the scope of the obviousness (e.g. in the case of thematically oriented events or serves health care, security or is done with the consent of the data subjects).The required information is identified as such within the scope of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information of the end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Use of online platforms for offering and sales purposes
We offer our services on online 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, addresses); 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Customers.
- Purposes of processing: provision of contractual services and customer service; marketing.
- Legal basis: Contract fulfillment and pre-contractual inquiries (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:
- Amazon: Online marketplace for e-commerce; Service provider: Amazon EU S.à r.l. (Société à responsabilité limitée), 38 avenue John F. Kennedy, L-1855 Luxembourg; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.amazon.de/; Privacy policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010; Basis third country transfer: Data Privacy Framework (DPF).
Providers and services used in the course of business
As part of our business operations, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.
- Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of contract, term, customer category).
- Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services); business and contractual partners; members; employees (e.g., employees, applicants, former employees).
- Purposes of processing: provision of contractual services and customer service; office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- DATEV: Software for accounting, communication with tax advisors and authorities and with document storage; Service provider: DATEV eG, Paumgartnerstr. 6 – 14, 90429 Nuremberg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.datev.de/web/de/mydatev/online-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/; Order processing contract: Provided by the service provider.
- Lexware: Software for invoicing, accounting, banking and tax filing with document storage; Service provider: Haufe Service Center GmbH, Munzinger Straße 9, 79111 Freiburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.lexoffice.de/datenschutz/; Privacy policy: https://datenschutz.lexware.de/.
Payment method
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively, “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy policy of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
- Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms).
- Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services).
- Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form).
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- Amazon Payments: Payment services (technical connection of online payment methods); Service provider: Amazon Payments Europe S.C.A. 38 avenue J.F. Kennedy, L-1855 Luxembourg; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://pay.amazon.de/; Privacy policy: https://pay.amazon.de/help/201212490.
- American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://www.americanexpress.com/de; privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.apple.com/de/apple-pay/; Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Flattr: Flattr – online payment and donation service; Service provider: Flattr AB, Box 4111, 203 12 Malmö, Sweden; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); website: https://flattr.com/; privacy policy: https://flattr.com/privacy.
- Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://pay.google.com/intl/de_de/about/; Privacy policy: https://policies.google.com/privacy.
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.mastercard.de/de-de.html; Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); 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; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://stripe.com; Privacy policy: https://stripe.com/de/privacy; Basis third country transfer: Data Privacy Framework (DPF).
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www.visa.de; Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
We process the users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).); security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Collection of access data and log files: Access to our online offer is logged in the form of 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 for security purposes, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
- E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Content Delivery Network: We use a “content delivery network” (CDN). A CDN is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Akamai: Content Delivery Network (CDN) – service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet; service provider: Akamai Technologies GmbH, Parkring 22, D-85748 Garching, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.akamai.com/de; Privacy policy: https://www.akamai.com/de/legal/compliance/privacy-trust-center; Order processing agreement: https://www.akamai.com/de/legal/compliance/privacy-trust-center (Akamai data processing agreement – for customers); Basis third country transfer: Standard Contractual Clauses (https://www.akamai.com/de/legal/compliance/privacy-trust-center (Cross-border data transfer)).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
- Types of data processed: inventory data (e.g. names, addresses); 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user-friendliness; security measures; administration and response to inquiries.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Comments and contributions: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.Furthermore, based on our legitimate interests, we reserve the right to process the information of users for the purpose of spam detection.On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Profile pictures from Gravatar: Profile pictures – We use the service Gravatar within our online offer and especially in the blog.Gravatar is a service where users can register and leave profile pictures and their email addresses. If users leave posts or comments on other online presences (especially blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of the transmission of the email address. It is not used for any other purpose, but is deleted afterwards.The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalize their posts with a profile picture.By displaying the pictures, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service. If users do not want a user image associated with their email address on Gravatar to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can completely prevent the transmission of data by not using our commenting system; service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy policy: https://automattic.com/privacy; Basis third country transfer: Data Privacy Framework (DPF).
- UpdraftPlus: Backup software and backup storage; Service provider: Simba Hosting Ltd, 11, Barringer Way, St. Neots, Cambs., PE19 1LW, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://updraftplus.com/; Privacy policy: https://updraftplus.com/data-protection-and-privacy-centre/.
Contact and request management
When contacting us (e.g. by mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
- 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partners.
- Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).
Communication via messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of Messenger with encryption enabled to ensure that message content is encrypted.
However, we also point out to our communication partners that the providers of the messengers cannot view the content, but they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messenger for the first time without your consent.
Revocation, objection and deletion: You may revoke any consent given and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.
- Types of data processed: contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partners.
- Purposes of processing: contact requests and communication; direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Instagram: Messaging via the social network Instagram; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger end-to-end encryption requires activation if it should not be activated by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Telegram Broadcasts: Telegram Broadcasts – Messenger with end-to-end encryption; Service provider: Telegram, Dubai; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://telegram.org/; Privacy policy: https://telegram.org/privacy.
- WhatsApp: WhatsApp Messenger with end-to-end encryption; Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.whatsapp.com/; Privacy policy: https://www.whatsapp.com/legal; Basis third country transfer: Data Privacy Framework (DPF).
Chatbots and chat functions
We offer online chats and chatbot functions (collectively referred to as “chat services”) as a communication option. A chat is an online conversation conducted with some timeliness. A chatbot is software that answers users’ questions or notifies them of messages. When you use our chat features, we may process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them according to legal requirements.
We would like to point out to users that the respective platform provider can find out that and when users communicate with our chat services as well as collect technical information about the device used by the users and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e., e.g., information about who communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertisements tailored to users in accordance with their terms and conditions, to which we refer for further information.
If users agree with a chatbot to activate information with regular messages, they have the option to unsubscribe from the information at any time in the future. The chatbot instructs users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages deletes users’ data from the list of message recipients.
We use the aforementioned information to operate our chat services, e.g., to personally address users, to respond to their inquiries, to deliver any requested content, and also to improve our chat services (e.g., to “teach” chatbots answers to frequently asked questions or to recognize unanswered inquiries).
Notes on legal basis: We use chat services on the basis of consent if we have previously obtained users’ permission to process their data as part of our chat services (this applies to cases where users are asked for consent, e.g., for a chatbot to send them messages on a regular basis). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimizing the chat services, their operational efficiency, and increasing the positive user experience.
Revocation, objection and deletion: You can revoke a given consent or object to the processing of your data within the scope of our chat services at any time.
- 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partners.
- Purposes of processing: contact requests and communication; direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements.
Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants’ terminal devices, their operating system, the browser and its technical and language settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent – if necessary.
Data privacy measures of the participants: Please observe the data privacy notices of the conference platforms regarding the details of the processing of your data and select the security and data privacy settings that are optimal for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorized third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g., consent to a recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g., in lists of participants, in the case of reprocessing of call results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Types of data processed: inventory data (e.g. names, addresses); 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Communication partners; Users (e.g., website visitors, users of online services); Persons depicted.
- Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organizational procedures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Twitch: Chats and live streams; Service provider: Twitch Interactive, Inc., 350 Bush Street, 2nd Floor, San Francisco, CA 94104, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.twitch.tv/; Privacy policy: https://www.twitch.tv/p/de-de/legal/privacy-notice/.
- Zoom: Conferencing and communication software; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Order Processing Agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA); Basis Third Country Transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA)).
Audio content
We use hosting and analytics services provided by service providers to offer our audio content for listening or downloading and to obtain statistical information about the retrieval of the audio content.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Podigee: Podcast hosting and statistical analysis of podcast views; Service provider: Podigee GmbH, Schlesische Straße 20, 10997 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.podigee.com/de; Privacy policy: https://www.podigee.com/de/about/privacy/.
Cloud services
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimization.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g., in the case of media control).
- Types of data processed: inventory data (e.g. names, addresses); 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Customers; employees (e.g., employees, applicants, former employees); prospective customers; communication partners; users (e.g., website visitors, users of online services).
- Purposes of processing: office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Google Cloud Storage: Cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://cloud.google.com/; Privacy Policy: https://policies.google.com/privacy; Order Processing Agreement: https://cloud.google.com/terms/data-processing-addendum; Basis Third Country Transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause; Further Information: https://cloud.google.com/privacy.
- Google Workspace: Cloud-based application software (e.g. text and spreadsheet editing, appointment and contact management), cloud storage and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://workspace.google.com/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://cloud.google.com/terms/eu-model-contract-clause; Further information: https://cloud.google.com/privacy.
- Microsoft Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Legal basis: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Order processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, 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 address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. 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.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times); content data (e.g. entries in online forms).
- Data subjects: Communication partners; users (e.g., website visitors, users of online services).
- Purposes of processing: direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Option to object (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 otherwise use one of the above contact options, preferably e-mail, for this purpose.
Further guidance on processing operations, procedures and services:
- Measurement of opening and click-through rates: 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, if we use a shipping service provider, from their server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognize 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 measurement of opening rates and click-through rates as well as storage of the measurement results in the profiles of the users and their further processing are based on the consent 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 it must be contradicted. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Order process reminder emails: If users do not complete an order process, we can remind users of the order process by email and send them a link to continue it. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. The dispatch is based on consent, which users can revoke at any time; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Promotional communication via e-mail, mail, fax or telephone
We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.
After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation or objection of the users, we further store the data required to avoid a renewed contact (e.g., depending on the communication channel, the e-mail address, telephone number, name).
- Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Sweepstakes and contests
We process personal data of participants of sweepstakes and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and execution of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g., in the security of the sweepstakes or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstakes entries).
If contributions from participants are published as part of the sweepstakes (e.g. as part of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we would like to point out that the names of the participants may also be published in this context. The participants can object to this at any time.
If the sweepstakes takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the sweepstakes and that inquiries with regard to the sweepstakes should be directed to us.
The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries about the competition are to be expected. In principle, the participants’ data will be deleted no later than 6 months after the end of the sweepstakes. Winners’ data may be retained for longer in order, for example, to be able to answer queries about the prizes or to fulfill the prize services; in this case, the retention period depends on the type of prize and is up to three years, for example, in the case of goods or services, in order, for example, to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reporting on the sweepstakes in online and offline media.
If data was also collected for other purposes within the scope of the competition, its processing and the retention period will be governed by the data protection information on this use (e.g. in the case of registration for the newsletter within the scope of a competition).
- Types of data processed: inventory data (e.g., names, addresses); content data (e.g., entries in online forms); meta, communication, and process data (e.g., IP addresses, time information, identification numbers, consent status).
- Affected persons: Sweepstakes and contest participants.
- Purposes of processing: implementation of sweepstakes and contests.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Surveys and polls
We conduct surveys and interviews in order to collect information for the respective communicated survey or interview purpose. The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed with the aid of a cookie).
- 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner; Participant.
- Purposes of processing: feedback (e.g. collecting feedback via online form).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- LimeSurvey: Conducting online surveys; Service provider: LimeSurvey GmbH Umfragedienste & Beratung, Papenreye 63, 22453 Hamburg, Germany; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); website: https://www.limesurvey.org/de; privacy policy: https://www.limesurvey.org/de/datenschutzinformation.
Web analysis, monitoring and optimization
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization.
In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, 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.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: remarketing; targeting; reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); provision of our online offer and user friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Google Optimize: Software for the analysis and optimization of online offers on the basis of feedback functions as well as pseudonymously performed measurements and analyses of user behavior, which may include in particular A/B tests (measurement of popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) p. 1 lit. a) DSGVO); Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as data processed).
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Google Analytics, geographic location data is processed at a higher level by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users’ IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses ( 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).
- Targeting with Google Analytics: We use Google Analytics to display the ads placed through within advertising services of Google and its partners, only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called “Remarketing Audiences”, or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of users; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Legal basis: https://business.safety.google/adsprocessorterms/; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms/; Basis third country transfer: Data Privacy Framework (DPF); Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses ( https://business.safety.google/adsprocessorterms.
- VG Wort / Scalable Central Measurement Procedure: VG Wort / Scalable Central Measurement Procedure – We use “session cookies” from VG Wort, Munich, to measure accesses to texts in order to record the probability of copying. Session cookies are small units of information that a provider stores in the RAM of the visitor’s computer. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. Session cookies cannot store any other data. These measurements are carried out by Kantar Germany GmbH using the Scalable Central Measurement Method (SZM). They help to determine the copy probability of individual texts for the remuneration of legal claims of authors and publishers. We do not collect any personal data via cookies.In the Scalable Central Measurement Method, anonymous measurement values are collected. The access count measurement alternatively uses a session cookie or a signature created from various automatically transmitted information from your browser to recognize computer systems. IP addresses are only processed in anonymized form. The procedure was developed in compliance with data protection. The sole aim of the procedure is to determine the copying probability of individual texts. At no time are individual users identified. Your identity always remains protected. You will not receive any advertising via the system; service provider: Verwertungsgesellschaft WORT (VG WORT), Untere Weidenstraße 5, 81543 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.vgwort.de; Privacy policy: https://www.vgwort.de/hilfsseiten/datenschutz.html.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “Content”) based on users’ potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles with the aforementioned data. We ask that you note that users can make additional agreements with the providers, e.g., by giving their consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
- 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, and procedural data (e.g., IP addresses, time data, identification numbers, consent status); Event data (Facebook) (“Event data” is data that can be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or in other ways), and relates to individuals or their actions; The data includes, e.g., information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; The event data is used for the purpose of forming target groups for content and advertising information. 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 forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and phone 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).
- Data subjects: 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/behavior-based profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiling with user-related information (creation of user profiles); provision of our online offer and user friendliness.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.
Further guidance on processing operations, procedures and services:
- Meta pixel and target group formation (Custom Audiences): With the help of the Meta pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for the Meta company, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Meta ads”). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on platforms of Meta and within the services of partners cooperating with Meta (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the web pages visited) that we transmit to Meta (so-called “Custom Audiences”). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Meta Pixel, we can further track the effectiveness of the Meta Ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta Ad (so-called “conversion measurement”); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis third country transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum); Further information: User Event Data, i.e., behavioral and interest data, is processed for the purposes of targeted advertising and audience building based on the Shared Responsibility Agreement (“Controller Addendum,” https://www.facebook.com/legal/controller_addendum). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
Customer reviews and evaluation process
We participate in review and rating procedures in order to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the privacy notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
- Types of data processed: contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Customers; Users (e.g., website visitors, users of online services).
- Purposes of processing: feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. To do this, a data connection must be established from the website called up within our online offering to the widget provider’s server, and the widget provider receives certain technical data (access data, including IP address) that are necessary so that the widget’s content can be delivered to the user’s browser.Furthermore, the widget provider receives information about the fact that users have visited our online offering. This information may be stored in a cookie and used by the widget provider to identify which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Google Customer Reviews: Service for obtaining and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Terms and conditions: https://support.google.com/merchants/topic/7259129?hl=de&ref_topic=7257954; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF); Further information: In the context of obtaining customer reviews, an identification number as well as time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address as well as their country of residence information as well as the review information itself are processed; Further information on the types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information on the Services Data Processing Terms between Controllers and Standard Contractual Clauses for Third Country Transfers of Data: https://business.safety.google/adscontrollerterms.
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, the enforcement of the users’ rights could be made more difficult.
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 behavior 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 behavior and 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 privacy statements and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- 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 guidance on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (known as a “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 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 regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests 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; Legal Grounds: Legitimate Interests (Art. 6 (1) p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis Third Country Transfer: Data Privacy Framework (DPF), Standard Contractual Clauses (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. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basis third country transfer: Standard Contractual Clauses (https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.pinterest.com; Privacy policy: https://policy.pinterest.com/de/privacy-policy; Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
- Snapchat: Social network; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.snapchat.com/; Privacy policy: https://www.snap.com/de-DE/privacy/privacy-policy; Basis third country transfer: Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).
- Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF); Opt-out: https://adssettings.google.com/authenticated.
- Social Media Wall / Social Media Newsroom: A “social media wall” or “social media newsroom” is a compilation of posts from various social networks in which we are mentioned or which contain a hashtag with our name or the name of a campaign. This includes mentions of posts we publish on social networks and posts published by users. The content of the posts is automatically obtained from the respective social networks in accordance with the terms and permissions of the authors, and users may object to the display at any time. The authors are generally responsible for the content of the posts. The providers of the respective social networks are responsible for the processing of data in connection with the display of the posts and their content. We refer to the information on the respective social networks within the scope of this privacy policy. Without prejudice to the data subject rights of users, we recommend that users (also) contact the respective authors or providers of the respective social networks in the event of requests for information and complaints about posts that were not written by us, in order to remove the posts at the source or to assert your data protection rights; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO).
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyze 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 about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.
- Types of data processed: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status); Inventory data (e.g., names, addresses); Contact data (e.g., email, phone numbers); Content data (e.g., entries in online forms); Location data (information about the geographic position of a device or person); Event data (Facebook) (“Event data” is data that, for example. via Facebook Pixel (via Apps or in other ways) can be transmitted by us to Facebook and relate to persons or their actions; 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 forming target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and phone 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).
- 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; marketing; profiles with user-related information (creation of user profiles).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimization of their offer. – We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process this for the purpose of transmitting the software to the users’ browsers and for security purposes, as well as for the evaluation and optimization of their offer; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Facebook plugins and content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos or text and buttons that allow users to 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/ – We are jointly responsible withMeta Platforms Ireland Limited for the collection or receipt in the course of any transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of any transmission by means of the Facebook Social Plugins (and content embedding features) running on our Online Offer for the purposes of: a) displaying content as well as promotional information that is relevant to users’ presumed interests; b) delivering commercial and transactional messages (e. g. e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users’ interests). We have entered into a special agreement with Facebook (“Addendum for Responsible Parties”, 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 fulfill data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather under a data processing contract (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms and Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis third country transfer: Data Privacy Framework (DPF).
- Google Fonts (sourcing from Google server): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols in terms of timeliness and loading times, their uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the provider of the fonts in the USA – When visiting our online offer, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts’ cascading style sheets (CSS) and then with the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e., the web page where the Google font is to be displayed). IP addresses are not logged or stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must match the font that is generated for the particular browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregate usage statistics that measure the popularity of font families. These aggregate usage statistics are published on Google Fonts’ Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregate report on top integrations based on the number of font requests. Google says it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users; service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF).
- Google Maps APIs and SDKs: Interfaces to Google’s map and location services that allow, for example, supplementing address entries, location determinations, distance calculations or provision of supplementary information on locations and other places; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF).
- Instagram Plugins and Content: Instagram Plugins and Content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this Online Service within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for collecting or receiving in the course of a transmission (but not further processing) “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Offer for the purposes of: a) displaying content as well as promotional information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g., targeting users via Instagram); c) providing commercial and transactional messages (e.g., targeting users via Instagram). e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users’ interests). We have entered into a special agreement with Facebook (“Addendum for Responsible Parties”, 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 fulfill data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather under a data processing contract (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data Security Terms and Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- LinkedIn Plugins and Content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Basis third country transfer: Standard Contractual Clauses (https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- OpenStreetMap: We incorporate the maps of the service “OpenStreetMap”, which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). User data is used by OpenStreetMap solely for the purposes of displaying the map functions and for caching the selected settings. This data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the settings of their mobile devices); Service Provider: OpenStreetMap Foundation (OSMF); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.openstreetmap.de; Privacy policy: https://wiki.osmfoundation.org/wiki/Privacy_Policy.
- reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies as well as results of manual recognition processes (e.g. answering questions asked or selecting objects in images). The data processing is carried out on the basis of our legitimate interest in protecting our online offering from abusive automated crawling and spam; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF); Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
- Twitter plugins and content: Twitter plugins and buttons – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Twitter; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent Company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://twitter.com/de; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization); Order processing agreement: https://privacy.twitter.com/en/for-our-partners/global-dpa; Basis third country transfer: Standard Contractual Clauses (https://privacy.twitter.com/en/for-our-partners/global-dpa.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis third country transfer: Data Privacy Framework (DPF); Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.