Disclaimer: The model below has been prepared by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV) Certified Data Protection Officer (TÜV Süd)) has been created according to the typical requirements of an online shop. However, you should only use the template after careful examination and adaptation to your specific business model. The following sample therefore contains additional notes that you must observe and red passages that you must particularly check and adapt if necessary. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the design within the domain/website as long as your Marketpress licence also applies to it. Passing on to third parties, including customers (e.g. as developers) is not permitted.
Privacy policy
Introduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") 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 in the context of the provision of our services and in particular on our websites, mobile, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
Stand: XX.XX.20XX
Please indicate the status of the privacy policy.
Table of contents
- Introduction
- Responsible
- Overview of the processing
- Contact Data Protection Officer
- Relevant legal bases
- Security measures
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Commercial and business services
- Payment service provider
- Credit check
- Provision of the online offer and web hosting
- Contact
- Newsletter and electronic notifications
- Web analysis, monitoring and optimisation
- Online marketing
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Data deletion
- Amendment and update of the privacy policy
- Rights of the data subjects
- Definitions of terms
Responsible
First name, last name / Company
Street, house no.
Postcode, place
Country
E-mail address: Your email address
Phone: Your telephone number (optional)
Imprint: URL of your imprint (optional, but recommended)
Notes: Please use the designation "owner" and not "managing director" for sole proprietors.
Contact Data Protection Officer
First name, last name / Company
Street, house no.
Postcode, place
Country
Note: Only the e-mail address is mandatory, the other information is optional. Data protection officers only have to be specified if they have been appointed. According to Section 38 of the new BDSG, an appointment is already required for 20 or more employees who process personal data (for which an e-mail box is practically sufficient).
Overview of the processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Note: The following details include the typical data processed and categories of data subjects (these themselves, as well as the explanations in brackets, are for clarification only and may be adapted or deleted).
Types of data processed
- Inventory data (e.g. names, addresses).
- Content data (e.g. entries in online forms).
- Contact details (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (information on the geographical position of a device or person).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of persons concerned
- Business and contractual partners.
- Interested parties.
- Communication partner.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of the processing
- Assessment of creditworthiness and credit standing.
- Provision of our online offer and user-friendliness.
- Visit action evaluation.
- Office and organisational procedures.
- Cross-device tracking (processing of user data across devices for marketing purposes).
- Direct marketing (e.g. by e-mail or post).
- Interest-based and behavioural marketing.
- Contact requests and communication.
- Conversion measurement (measuring the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Remarketing.
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- Safety measures.
- Tracking (e.g. interest/behavioural profiling, use of cookies).
- Provision of contractual services and customer service.
- Managing and responding to enquiries.
- Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Automated decisions in individual cases
- Credit report (decision based on a credit check).
Relevant legal bases
In the following, we inform you about the legal basis of the Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection provisions in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) - The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject's request.
- Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
Security measures
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, entry, disclosure, assurance of availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https)To protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Note: Remove the reference to encryption if your offer is not encrypted. However, delivery of the website via https is to be considered mandatory.
Transfer and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide a telemedia service (i.e. our online offer) expressly requested by the users. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Information on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures.
Storage period: With regard to the storage period, 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 their end device (e.g. browser or mobile app).
- General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (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 made by means of a variety of services, especially in the case of tracking, via the web pages https://optout.aboutads.info and https://www.youronlinechoices.com/ be declared. In addition, you can receive further instructions on how to object within the scope of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by the users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.
Cookie settings/ objection option:
If you use a cookie consent banner (which is recommended), you can enter the option to call it up at this point (e.g. link or a so-called [shortcode], which is automatically converted into a button/link by your software).
Notes on processing cookie data on the basis of consent: You should only leave this option (and otherwise delete it) if you obtain a "real" opt-in, i.e., user consent to the use of cookies (e.g., with so-called "cookie consent/consent/opt-in banners" or as part of a registration procedure).
Since a cookie opt-in is usually necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g. Google Analytics or Facebook Pixel), this option is preselected.
This means that you do not use cookies (and do not use third-party services within your websites that themselves use cookies) until the users have given their consent. At most, the use of necessary cookies that users expect, such as a shopping cart function in the online shop or local reach measurement with the Matomo tool, is permissible.
Commercial and 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 enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organisation. We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The 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 of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after the expiry of 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Customer accountContractual partners can create an account within our online offer (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this as well as of the details required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their account is terminated.
Economic analyses and market researchFor business reasons and in order to be able to recognise market trends, wishes of contractual partners and users, we analyse the data we have on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). Where available, we may take into account the profiles of registered users together with their details, e.g. services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).
Shop and e-commerceWe process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated 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 for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to consult with you if necessary.
- 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 data (e.g. device information, IP addresses).
- Persons concerned: Interested parties, business and contractual partners, customers.
- Purposes of the processing: Provision of contractual services and customer service, contact requests and communication, office and organisational procedures, administration and response to requests, security measures, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles).
- Legal basis: Contract performance and pre-contractual enquiries (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).
Note: Please remove the passage on customer account or analysis of customer data if you do not offer a customer account or do not analyse your customers' data as described.
Payment service provider
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to data subjects and use other payment service providers in addition to banks and credit institutions for this purpose (collectively "payment service providers").
The data processed by the payment service providers include 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, sum and recipient-related details. The information is required 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 data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the 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 data (e.g. device information, IP addresses).
- Persons concerned: Customers, interested parties.
- Purposes of the processing: Provision of contractual services and customer service.
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- PayPal: Payment services and solutions (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; Website: https://www.paypal.com/de; Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Otherwise, adjust the list of services and providers as necessary.
Credit check
If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from service companies specialising in this field (credit agencies) in order to safeguard our legitimate interests.
We process the information received from the credit agencies on the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance performance in the event of a negative result of the credit check.
In accordance with Art. 22 DSGVO, the decision as to whether we provide advance payment is made solely on the basis of an automated decision in the individual case, which is made by our software on the basis of the information provided by the credit agency.
If we obtain express consent from contractual partners, the legal basis for the credit rating information and the transmission of the customer's data to the credit agencies is the consent. If no consent is obtained, the creditworthiness information is provided on the basis of our legitimate interests in the default security of our payment claims.
- 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).
- Persons concerned: Customers, interested parties.
- Purposes of the processing: Assessment of creditworthiness and credit standing.
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
- Automated decisions in individual cases: Credit report (decision based on a credit check).
Services used and service providers:
- Verband der Vereine Creditreform e.V.: Credit reference agency; Service provider: Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany; Website: https://www.creditreform.de/; Privacy policy: https://www.creditreform.de/datenschutz.
Note: Remove the credit check passage if you do not perform a credit check. Check and change the list of service providers if necessary. Checking the creditworthiness of a customer is permissible if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses purchase on account). In contrast, there is no risk of non-payment if the customer chooses, for example, the prepayment option or makes the payment via third-party providers, such as Paypal.
It should also be noted that obtaining an automatic credit report is an "automated decision in an individual case" pursuant to Art. 22 of the GDPR, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is necessary has not yet been conclusively clarified, but is often taken as a given, including by the author of this sample.
However, if you want to exclude any risk, you should obtain consent. Consent is also necessary if the credit check is already used to decide whether the option "on account" should be displayed. This is because it could have been that the customer would have decided to pay in advance or Paypal anyway and the credit check would not have been necessary. Such consent could, for example, read as follows:
I agree that a credit check is carried out in order to decide in an automated procedure (Art. 22 DSGVO) whether the option of purchase on account is offered. For more information on the credit check, the credit agencies used and the procedure as well as the objection options, please see our [Link]Privacy Policy[/Link].
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hostingThe web hosting services we use also include the sending, receiving and storing 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 the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure 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.
Collection of access data and log filesWe ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of the access, the amount 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 can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilisation of the servers and their stability.
- Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Note: If you have not already done so: Please ask the respective web hoster for a so-called "order processing contract" (or "data processing agreement"). This is required by law because the hoster collects personal data of website visitors on your behalf.
Contact
When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact requests and any requested measures.
The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of the legitimate interests in responding to the requests.
- 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 data (e.g. device information, IP addresses).
- Persons concerned: Communication partners, interested parties.
- Purposes of the processing: Contact requests and communication, managing and responding to requests.
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Help Scout: Management of contact requests and communication; Service provider: Help Scout Inc, 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Privacy policy: https://www.helpscout.net/company/legal/privacy/Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://www.helpscout.com/company/legal/dpa/Order processing contract: https://www.helpscout.com/company/legal/dpa/.
Note: If third-party CRM systems are used, their providers should be named. Adjust this information or remove the specified service provider. Furthermore, order processing contracts (or "Data Processing Agreement") must be concluded with the providers. If the providers process the users' data in a third country, special guarantees must be in place (e.g. standard contractual clauses).
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. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the user. 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 a personal address in the newsletter, or further details if these are required 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 email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
erasure and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of 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 blacklist for this purpose alone.
The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal bases: Newsletters are sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Analysis and performance measurementThe 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 dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on 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 behaviour 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. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. Rather, we use the analyses to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of its success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or must be contradicted.
- Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
- Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the above contact options, preferably e-mail, for this purpose.
Services used and service providers:
- CleverReach: Email marketing platform; service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/Order processing contract: concluded with provider.
- Mailchimp: Email sending and email marketing platform; Service provider: "Mailchimp" - Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/privacy/Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://mailchimp.com/legal/data-processing-addendum/; Further information: Special safety measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Please delete the Newsletter section if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the information on newsletter content and performance measurement as necessary.
Web analysis, monitoring and optimisation
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise 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 need optimisation.
In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie") or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, 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 purpose of the respective procedures.
Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
- Safety measures: IP masking (pseudonymisation 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).
Services used and service providers:
- etracker: Web analytics/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https://www.etracker.com/datenschutz/Order processing contract: https://www.etracker.com/av-vertrag/.; Possibility of objection (opt-out): https://www.etracker.de/privacy?et=[PLEASE INSERT YOUR ACCOUNT ID].
- Matomo (without cookies): Matomo is a data protection-friendly web analysis software that is used without cookies and in which the recognition of returning users takes place with the help of a so-called "digital fingerprint", which is stored anonymously and changed every 24 hours; with the "digital fingerprint", user movements within our online offer are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected in the course of using Matomo is only processed by us and is not shared with third parties.
Please delete the passage Web analytics, monitoring and optimisation if you do not use any web analytics, monitoring and optimisation tools on your website. Adjust the list of services and providers if necessary. Note: Matomo is declared in the version without cookies.
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 information about the user relevant to 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. 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. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope 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 analysed 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 you to 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 summarised information about the success of our advertisements. However, within the framework 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 analyse 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.
Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person).
- Persons concerned: Users (e.g. website visitors, users of online services), interested parties.
- Purposes of the processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (processing of user data across devices for marketing purposes).
- Safety measures: IP masking (pseudonymisation 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).
- Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called "opt-out") given 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 the 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-territorial: https://optout.aboutads.info.
Services used and service providers:
- 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 offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user's IP address, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacyOrder processing contract: https://business.safety.google/adsprocessortermsFurther information: Types of processing and data processed: https://privacy.google.com/businesses/adsservicesData processing terms and conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Analytics: Reach measurement and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Option to object (Opt-Out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticatedOrder processing contract: https://business.safety.google/adsprocessorterms/Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservicesData processing terms and conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Google Ads and conversion measurement: We use the online marketing process "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called "conversion tracking tag". However, we ourselves do not receive any information with which users can be identified; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website:https://marketingplatform.google.com; Privacy policy:https://policies.google.com/privacyFurther information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms and conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Google Ad Manager: We use the Google Marketing Platform (and services such as Google Ad Manager) to place ads on the Google advertising network (e.g. in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterised by the fact that ads are displayed in real time based on the presumed interests of the users. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. For example, if a user is shown ads for products they have been interested in on other online services, this is known as "remarketing"; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacyFurther information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms and conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollertermsWhere Google acts as a processor, data processing terms and conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Facebook pixel and targeting (Custom Audiences): With the help of the Facebook pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to such users on Facebook and within the services of partners cooperating with Facebook (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 evident from the web pages visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; standard contractual clauses (guaranteeing level of data protection for processing in third countries): The "Facebook EU Data Transfer Addendum" (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of commissioned processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the "Facebook Platform Terms of Use" (https://developers.facebook.com/terms) with regard to Facebook's own processing of event data in the context of ad placement; Further information: The "Data Processing Terms and Conditions" (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf to provide reporting and analysis to companies; Furthermore, the "Controller Addendum" applies as an agreement on joint responsibility (Art. 26 para. 1 sentence 3 of the GDPR), which is relevant in the case of the autonomous processing of event data by Facebook for the purposes of targeting as well as improving and securing Facebook products.
Please delete the passage Online marketing if you do not use any online marketing tools on your website. Adjust the list of services and providers as necessary. Please bear in mind that the use of marketing services on the website usually requires a cookie opt-in.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it may be more difficult to enforce the rights of the users.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of 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: 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 data (e.g. device information, IP addresses).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
- Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Facebook Ireland Ltd. for the collection (but not further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (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 Privacy 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 the content associated with them. We have entered into a specific 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 fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policyStandard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://legal.linkedin.com/dpa; Possibility of objection (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-outOrder processing contract: https://legal.linkedin.com/dpa.
- 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; 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; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy Policy: https://policies.google.com/privacy; Possibility of objection (Opt-Out): https://adssettings.google.com/authenticated.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
Adjust the list of social networks if necessary.
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 social media buttons and posts (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, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyse 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 offering, as well as being linked to such information from other sources.
Notes on legal bases: Where we ask users to consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Persons concerned: Users (e.g. website visitors, users of online services), communication partners.
- Purposes of the processing: Provision of our online offering and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, administration and response to requests.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).
Services used and service providers:
- 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 with Facebook Ireland Ltd. we are jointly responsible with Facebook Ireland Ltd. for collecting or receiving in connection with any transmission (but not further processing) of "event data" that Facebook collects or receives in connection with any transmission through the Facebook social plugins (and content embedding features) running on our website for the purposes of: a) displaying content and promotional information relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook social plugins) to users of our website. (c) improving ad delivery and personalising features and content (e.g., improving the identification of which content or advertising information is likely to be relevant to users' interests). We have entered into a specific agreement with Facebook ("Responsible Party Addendum", 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 comply with data subjects' 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 carried out under shared responsibility, but on the basis of a commissioned processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing) the "data security conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the 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: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy.
- Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
- Google Maps: We integrate the maps of the "Google Maps" service of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the framework of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Option to object (Opt-Out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
- reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called "bots"). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Option to object (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 with which users can share content of this online offer 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; Website:https://twitter.com/de; Privacy policy:https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube videos: Video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website:https://www.youtube.com; Privacy policy:https://policies.google.com/privacy; Option to object (Opt-Out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
- Vimeo: Video content; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacyOpt-out option: We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data use for marketing purposes (https://adssettings.google.com/).
Please delete the passage Plugins and embedded functions and content if you do not use plugins or embedded functions and content within your website. Otherwise, please adapt the list of services and providers as necessary.
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 is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Amendment and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.
Rights of the data subjects
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 are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right of withdrawal for consents: You have the right to revoke any consent you have given at any time.
- Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right of rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be corrected.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
- Right to data portability: You have the right to receive data relating to you that 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 person responsible.
- Complaint to supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
- Visit action evaluation: "Conversion tracking" refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful).
- Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application procedure without any human intervention. Such automated decisions are only allowed under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract or if national laws allow such decisions.
- Cross-device tracking: Cross-device tracking is a form of tracking in which users' behavioural and interest information is recorded across devices in so-called profiles by assigning an online identifier to the users. This allows user information to be analysed for marketing purposes regardless of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
- IP masking: IP masking" is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing
- Interest-based and behavioural marketing: Interest-based and/or behaviour-based marketing is when the potential interests of users in advertisements and other content are determined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiling: Profiling" is any form of automated processing of personal data which consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: Remarketing" or "retargeting" is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
- Tracking: Tracking" is when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information with regard to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Responsible: Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
- Target group formation: We speak of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. insertion of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he or she viewed the products. In turn, we speak of "lookalike audiences" (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.