data protection
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This 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, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
Status: December 15, 2024
table of contents
- Introduction
- responsible person
- Overview of processing
- Contact Data Protection Officer
- Relevant legal bases
- security measures
- transmission and disclosure of personal data
- data processing in third countries
- use of cookies
- Commercial and business services
- payment service providers
- credit check
- provision of the online offer and web hosting
- contact
- newsletters and electronic notifications
- web analysis, monitoring and optimization
- online marketing
- Presences in social networks (social media)
- Plugins and embedded functions and content
- deletion of data
- Change and update of the privacy policy
- rights of the data subjects
- definitions of terms
responsible person
Name/Company: Markus Stöger
Street No.: Lehmhäusl 23
ZIP code, city, country: 3261, Steinakirchen, Austria
Telephone number: +43 (660) 32 66 497
E-mail address: office@TextSnapper.com
Imprint:
Contact Data Protection Officer
E-mail address: office@TextSnapper.com
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
types of data processed
- Inventory data (e.g. names, addresses).
- Content data (e.g. entries in online forms).
- Contact details (e.g. email, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (information about 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 data subjects
- business and contractual partners.
- Users (e.g. website visitors, users of online services).
purposes of processing
- Assessment of creditworthiness and credit rating.
- Provision of our online offering and user-friendliness.
- office and organizational procedures.
- Cross-device tracking (cross-device processing of user data for marketing purposes).
- Direct marketing (e.g. by email or post).
- Interest-based and behavioral marketing.
- contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- security measures.
- Tracking (e.g. interest-/behavioral profiling, use of cookies).
- Provision of contractual services and customer service.
- Managing and responding to inquiries.
- 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
Below we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Article 6, Paragraph 1, Sentence 1, Letter a. of GDPR)– The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR)– Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Article 6, paragraph 1, sentence 1, letter c. GDPR)– Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR)– Processing is necessary to protect 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 protection of personal data.
security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
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 access, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect the data you transmit via our website. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
transmission and disclosure of personal data
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions as part 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 appropriate contracts or agreements with the recipients of your data that serve to protect your data.
data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transmission, we only process or have the data processed in third countries with a recognized 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 GDPR, 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 storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service that they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to users and contains information on the respective cookie usage.
Notes on data protection legal bases: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
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 offering and closed his or her device (e.g. browser or mobile application).
- Persistent cookies:Permanent cookies remain stored even after the 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. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period 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 (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using the settings in your browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be made using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ You can also receive further information about your objection in the information on the service providers and cookies used.
Processing of cookie data based on consent: We use a cookie consent management process within which users' consent to the use of cookies or the processing and providers named in the cookie consent management process can be obtained and managed and revoked by users. The declaration of consent is saved so that it does not have to be requested again and consent can be proven in accordance with the legal obligation. 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 about the providers of cookie management services, the following information applies: The consent can be stored for up to two years. A pseudonymous user identifier is created and saved with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and device used.
Cookie settings/opt-out option:
Change privacy settings
history of privacy settings
revoke consent
Information on the processing of cookie data based on consent:
Since a cookie opt-in is generally necessary according to the ECJ when using marketing tools commonly used in e-commerce (e.g. Google Analytics or Facebook Pixel), this option is preselected.
This means that you should not use any cookies (and should not use any third-party services within your websites that use cookies themselves) until users have given their consent. The use of necessary cookies that are expected by users is only permitted, such as a shopping cart function in the online shop or local reach measurement using the Matomo tool.
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”) within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations, to protect our rights and for the purposes of the administrative tasks associated with this information and for business organization. Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill 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 are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and similar obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., for as long as it must be kept for legal archiving reasons (e.g., for tax purposes, usually 10 years). We delete data that was disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
To the extent that 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 to the relationship between the users and the providers.
customer account: Contractual partners can create an account within our online offering (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we save the customers’ IP addresses along with the access times in order to be able to prove registration and 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 customer's responsibility to back up their data when the customer account is terminated.
Economic analysis and market research: For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, inquiries, 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 purposes of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can take into account the profiles of registered users, if available, along with their information, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of the users into account and process the data for the analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as summarized data).
Shop and E-Commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultation.
- 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 the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons:Interested parties, business and contractual partners, customers.
- Purposes of processing:Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to inquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
- Legal basis:Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
payment service providers
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other payment service providers (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information confirming or rejecting the payment. The payment service providers may transmit the data to credit agencies. This transmission is for the purpose of checking identity and creditworthiness. For this purpose, we refer to the 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 payment transactions and can be accessed on the respective websites or transaction applications. We also refer to these for further information and to assert revocation, information and other rights of those affected.
- 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 the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons:customers, interested parties.
- Purposes of processing:Provision of contractual services and customer service.
- Legal basis:Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services and service providers used:
- PayPal:Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Stripe: We offer the option of processing the payment transaction via the payment service provider Stripe, ℅ Legal Process, 510, Townsend St., San Francisco, CA 94103 (Stripe). This corresponds to our legitimate interest in offering an efficient and secure payment method (Art. 6 Para. 1 lit. f GDPR). In this context, we pass on the following data to Stripe, insofar as it is necessary for the performance of the contract (Art. 6 Para. 1 lit b. GDPR).
name of the cardholder
E-mail address
customer number
order number
bank details
credit card information
validity period of the credit card
credit card verification code (CVC)
date and time of the transaction
transaction amount
name of the provider
Location
The processing of the data specified in this section is neither required by law nor by contract. Without the transmission of your personal data, we cannot process a payment via Stripe. [You have the option of choosing a different payment method.]
Stripe takes on a dual role as controller and processor in data processing activities. As the controller, Stripe uses your transmitted data to fulfill regulatory obligations. This corresponds to Stripe's legitimate interest (according to Art. 6 Para. 1 lit. f GDPR) and serves to execute the contract (according to Art. 6 Para. 1 lit. b GDPR). We have no influence on this process.
Stripe acts as a processor in order to complete transactions within the payment networks. As part of the order processing relationship, Stripe acts exclusively according to our instructions and has been contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.
Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).
For more information on objection and removal options with Stripe, please visit: https://stripe.com/privacy-center/legal
We will store your data until the payment is processed. This also includes the period required to process refunds, debt collection and fraud prevention. [According to [§ 147 AO / § 257 HGB], a statutory retention period of [X] years applies to us for the following documents: [ ]]
Legal Notice
address
Stripe Payments Europe Limited 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland Attention: Stripe Legal
credit check
If we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right, in order to protect our legitimate interests, to obtain an identity and credit report for the purpose of assessing the credit risk on the basis of mathematical and statistical procedures from service providers specializing in this area (credit reporting agencies).
We process the information received from the credit agencies on the statistical probability of a payment default as part 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 any other advance payment in the event of a negative result of the credit check.
The decision as to whether we make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision in the individual case, which our software makes 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 report and the transmission of the customer's data to the credit agencies is the consent. If no consent is obtained, the credit report is based on our legitimate interests in the reliability 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 of the contract, term, customer category).
- Affected persons:customers, interested parties.
- Purposes of processing:Assessment of creditworthiness and credit rating.
- Legal basis:Consent (Article 6 (1) sentence 1 lit. a. GDPR), legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
- Automated decisions in individual cases:Credit report (decision based on a credit check).
Services and service providers used:
- Association of Creditreform eV:Credit agency; Service provider: Association of Creditreform eV, Hellersbergstraße 12, D-41460 Neuss, Germany; Website: https://www.creditreform.de/; Privacy Policy: https://www.creditreform.de/datenschutz.
It should also be noted that obtaining an automatic credit report represents an "automated decision in individual cases" according to Art. 22 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 report is already being used to decide whether the "on account" option should be displayed. This is because the customer could have opted for advance payment or PayPal anyway and the credit check would not have been necessary. Such consent could, for example, be as follows:
ð I agree that a credit check will be carried out in order to decide in an automated process (Art. 22 GDPR) whether the option of purchase on account will be offered. Further information on the credit check, the credit agencies used and the process as well as the options for objection can be found in our [Link]Data Protection Policy[/Link].
provision of the online offer and web hosting
In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the context of providing the hosting service may include all information concerning the users of our online service that arises in the context of use and communication. This usually includes the IP address, which is necessary in order to be able to deliver the content of online services to browsers, and all entries made within our online service or on websites.
email sending and hosting: The web hosting services we use also include the sending, receiving and storing of emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the email sending (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that emails are generally not sent encrypted on the Internet. Emails are usually encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of emails between the sender and the recipient on our server.
collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the web pages and files accessed, the date and time of 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 for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization 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).
- Affected persons:Users (e.g. website visitors, users of online services).
- Legal basis:Legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
contact
When you contact us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact requests and any requested measures.
Contact requests within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre)contractual requests and otherwise on the basis of legitimate interests in answering 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).
- Affected persons:communication partners, interested parties.
- Purposes of processing:Contact requests and communication, administration and response to inquiries.
- Legal basis:Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
newsletters and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out using 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 using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a blocking list (so-called "blacklist") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Notes on legal basis: The newsletter is sent based on the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send emails, 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 success measurement: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected.
This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using 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 individual newsletter recipients. However, it is neither our aim nor that of the shipping service provider, if used, to observe individual users. Rather, the evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked.
- 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).
- Affected persons:
- Purposes of processing:Direct marketing (e.g. by email or post).
- Legal basis:Consent (Article 6 (1) sentence 1 lit. a. GDPR), legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
- Opt-out option:You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Services and service providers used:
- ActiveCampaign Privacy Policy
Active Campaign Privacy Policy Summary
Affected parties: newsletter subscribers
Purpose: Direct marketing by email, notification of system-relevant events
Processed data: Data entered during registration, but at least the email address.
Storage period: Duration of the subscription
Legal basis: Art. 6 para. 1 lit. a GDPR (consent), Art. 6 para. 1 lit. f GDPR (legitimate interests)
We use the newsletter to inform you about us and our offers. If you would like to receive the newsletter, we need a valid email address from you as well as information that allows us to verify that you are the owner of the email address provided or that the owner of the address agrees to receive the newsletter. In addition, we ask for your first name to personalize our newsletter, but this information is provided voluntarily. No further data is collected. This data is only used to send the newsletter and is not passed on to third parties. When you register for the newsletter, we save your IP address and the date of registration. This storage serves solely as evidence in the event that a third party misuses an email address and registers to receive the newsletter without the knowledge of the authorized person. You can revoke your consent to the storage of the data, the email address and their use to send the newsletter at any time. You can revoke your consent via a link in the newsletters themselves, in your profile area or by sending a message to the contact options above.
Information about newsletters and consents?
With the following information we will inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter you agree to receive it and to the procedures described.
content of the newsletter
We only send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Our newsletters also contain information about our products and our company (this can include references to blog posts, lectures or workshops, our services or online presence).
Double opt-in and logging?
Registration for our newsletter is carried out using 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 using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address.
Use of the shipping service provider "Active Campaign"
The newsletter is sent via “Activecampaign”, a newsletter distribution platform of the US provider ActiveCampaign, LLC, 150 N. Michigan Ave Suite 1230, Chicago, IL, US, USA.
The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on ActiveCampaign's servers in the USA. ActiveCampaign uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, ActiveCampaign can use this data to optimize or improve its own services, e.g. to technically optimize the sending and presentation of the newsletter or for commercial purposes in order to determine which countries the recipients come from. However, ActiveCampaign does not use the data of our newsletter recipients to write to them directly and does not pass the data on to third parties.
We trust in the reliability and IT and data security of ActiveCampaign. ActiveCampaign is certified under the EU-US Privacy Shield data protection agreement and is therefore committed to complying with EU data protection regulations. We have concluded a data processing agreement with the provider in accordance with a contract for order processing in accordance with Art. 28 GDPR. You can find ActiveCampaign's data protection regulations here. ActiveCampaign also protects our newsletter subscribers with a comprehensive anti-spam policy.
login details
To subscribe to the newsletter, simply provide your email address.
Statistical Survey and Analysis
The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the ActiveCampaign server when the newsletter is opened. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times.
The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our aim nor that of ActiveCampaign to monitor individual users. The evaluations are much more useful for 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.
online access and data management
There are cases in which we direct newsletter recipients to ActiveCampaign's websites. For example, our newsletters contain a link that newsletter recipients can use to access the newsletter online (e.g. if there are display problems in the email program). Newsletter recipients can also subsequently correct their data, such as their email address. ActiveCampaign's privacy policy is also only available on their website.
In this context, we would like to point out that cookies are used on the ActiveCampaign websites and that personal data is therefore processed by ActiveCampaign, its partners and the service providers used (e.g. Google Analytics). We have no influence on this data collection. We would also like to draw your attention to the options for objecting to the collection of data for advertising purposes on the websites https://www.aboutads.info/choices/ and https://www.youronlinechoices.com/ (for Europe).
termination/revocation
You can cancel your subscription to our newsletter at any time, i.e. revoke your consent. This also means that your consent to our sending via ActiveCampaign and the statistical analyses will expire. It is not possible to revoke your subscription to our newsletter or the statistical analyses separately. You will find a link to cancel your newsletter subscription at the end of each newsletter.
web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, different versions of our online offering or its components.
For these purposes, so-called user profiles can be created and saved in a file (so-called "cookie") or similar procedures can be used for the same purpose. This information can 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 can also be processed depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of data processed:Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: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-related profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
- Safety measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Article 6 (1) sentence 1 lit. a. GDPR), legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
Services and service providers used:
- etracker:Web analysis/reach measurement; service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; website: https://www.etracker.com; Privacy Policy: https://www.etracker.com/datenschutz/; Data processing agreement: 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 privacy-friendly web analysis software that is used without cookies and which recognizes returning users with the help of a so-called "digital fingerprint" that is stored anonymously and changed every 24 hours. With the "digital fingerprint", user movements within our online offering are recorded with the help of pseudonymized IP addresses in combination with user browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties.
online marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their 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 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 can 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 email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users' profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- 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 person).
- Affected persons:Users (e.g. website visitors, users of online services), interested parties.
- Purposes of processing:Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavior-related 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), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
- Safety measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Article 6 (1) sentence 1 lit. a. GDPR), legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
- Opt-out option:We refer to the data protection information of the respective providers and the objection options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Services and service providers used:
- Google Tag Manager:Google Tag Manager is a solution that allows us to 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). The Tag Manager itself (which implements the tags) therefore 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/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Further information: Types of processing and 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 Analytics:Reach measurement and web analysis; 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; Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Data processing agreement: https://business.safety.google/adsprocessorterms/; Further information: Types of processing and 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 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 websites, etc.) so that they are shown to users who are likely to be interested 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 with a so-called “conversion tracking tag”. However, we do not receive any information that can be used to identify users; 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/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services Data processing terms between 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 in the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she was interested on other online offerings, this is referred to 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/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as a processor, data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
- Facebook Pixel and target group creation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to determine the visitors to our online offering as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only show the Facebook ads placed by us to those 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 offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites 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 interests of users and do not appear annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (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 (ensuring data protection level when processing in third countries): The “Facebook EU Data Transfer Addendum” (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of order processing by Facebook as the basis for the processing of event data from EU citizens in the USA and the inclusion in the “Facebook Platform Terms of Use” (https://developers.facebook.com/terms) with regard to the independent processing of event data by Facebook in the context of advertising; Further information: The “Data Processing Terms” (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf of companies in order to provide reports and analyses; Furthermore, the “Addendum for Responsible Parties” is considered an agreement on joint responsibility (Article 26 Paragraph 1 Clause 3 GDPR), which is decisive in the case of Facebook’s independent processing of event data for the purposes of targeting and improving and securing Facebook products.
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the 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 users because it could, for example, make it more difficult to enforce user rights.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the user (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing methods and the options for objection (opt-out), please 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 user 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).
- Affected persons:Users (e.g. website visitors, users of online services).
- Purposes of processing:Contact requests and communication, tracking (e.g. interest-/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis:Legitimate interests (Article 6 (1) sentence 1 lit. f. GDPR).
Services and service providers used:
- 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 “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 "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 so that they can gain 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 in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of those affected (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 responsible 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 data protection levels when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Agreement on joint responsibility: 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-policy; Standard contractual clauses (ensuring data protection level when processing in third countries): https://legal.linkedin.com/dpa; Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Data processing agreement: 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.
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos or social media buttons as well as posts (hereinafter referred to uniformly 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 would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- 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 person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Affected persons:Users (e.g. website visitors, users of online services), communication partners.
- Purposes of processing:Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavior-related profiling, use of cookies), interest-based and behavior-related marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
- Legal basis:Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).
Services and service providers used:
- Facebook plugins and content: Facebook social plugins and content – This can include, for example, content such as images, videos or texts and buttons that users can use to share content from this website 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. for the collection or receipt during a transmission (but not the further processing) of “event data” that Facebook collects or receives during a transmission using the Facebook social plugins (and content embedding functions) that run on our website for the following purposes: a) displaying content and advertising information that corresponds to the presumed interests of users; b) delivering commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improving ad delivery and personalizing functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook (“Addendum for Controllers”, https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of the data subject (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), then this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement (“Data Processing Conditions”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Conditions” (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the 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 the right to information, deletion, objection and complaint to the responsible 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 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 provided by Google. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually carried out as part 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; Opt-out option: 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 recognize whether entries (e.g. in online forms) are made by people 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, keyboard strokes, 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; Opt-out option: 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 content such as images, videos or texts and buttons that users can use to share content from this website 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; Opt-out option: 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/privacy; Opt-out option: We would like to 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 usage for marketing purposes (https://adssettings.google.com/).
deletion of data
The data we process will be deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).
If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information 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 Articles 15 to 21 of the GDPR:
- Right of objection:You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; 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 your consent at any time.
- Right to information:You have the right to request confirmation as to whether or not data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification:In accordance with the statutory provisions, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
- Right to erasure and restriction of processing:In accordance with the statutory provisions, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability:You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
- Complaint to the supervisory authority:You also have the right, in accordance with the statutory provisions, 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 are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to help you understand. The terms are sorted alphabetically.
- Visit Action Evaluation:“Conversion tracking” is a process that can be used to determine the effectiveness of marketing measures. This usually involves storing a cookie on the user’s device within the websites on which the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to see whether the ads we have placed on other websites were 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 process without any human intervention). Such automated decisions are only permissible according to Art. 22 GDPR if the data subjects consent, if they are necessary for the performance of a contract or if national law permits these decisions.
- Cross-device tracking:Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This means that user information can usually be analyzed for marketing purposes regardless of the browser or device 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 email 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. IP masking is therefore a means of pseudonymizing processing procedures, especially in online marketing.
- Interest-based and behavioral marketing:Interest- and/or behavior-based marketing is when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done using information about their previous behavior (e.g. visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are usually used for these purposes.
- Conversion measurement:Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. This usually involves storing a cookie on the user's device within the websites on which the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to see whether the ads we have placed on other websites were successful.
- Personal data:“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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. a 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” refers to any form of automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning 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 known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, recognize 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 recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- 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 for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically definable position on earth of the respective device. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking:“Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information relating to the online offerings used is stored in cookies or on servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to correspond to their interests.
- Responsible:The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of processing personal data.
- Processing:“Processing” is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data, be it collection, evaluation, storage, transmission or deletion.
- Target group formation:Target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. displaying 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 viewed the products. “Lookalike audiences” (or similar target groups) are, in turn, when 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.