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Data Protection

Data protection declaration of "R211 – Agentur für Kommunikation"

1. Introduction

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” for short) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: January 8, 2021

2. Controller

Angela Kettler-Bott
R211-Agentur für Kommunikation
Florastraße 73
40217 Düsseldorf

E-Mail-Adresse: hello@r211-agentur.de
Telefon: +49 211 749 512 81
Impressum: https://r211-agentur.de/impressum/

3. Overview of processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  1. Event data (Facebook) (“Event data” is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or in other ways), and relates to people or their actions; The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from it with the deletion of our Facebook account).
  2. Inventory data (e.g. names, addresses).
  3. Content data (e.g. entries in online forms).
  4. Contact data (e.g. e-mail, telephone numbers).
  5. Meta/communication data (e.g. device information, IP addresses).
  6. Usage data (e.g. websites visited, interest in content, access times).
  7. Location data (information on the geographical position of a device or person).
  8. Contract data (e.g. subject matter of the contract, term, customer category).
  9. Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  1. Business and contractual partners.
  2. Interested parties.
  3. Communication partners.
  4. Customers.
  5. Users (e.g. website visitors, users of online services).

Purposes of processing

  1. Provision of our online offer and user-friendliness.
  2. Conversion measurement (measuring the effectiveness of marketing measures).
  3. Office and organizational procedures.
  4. Cross-device tracking (cross-device processing of user data for marketing purposes).
  5. Direct marketing (e.g. by e-mail or post).
  6. Feedback (e.g. collecting feedback via online form).
  7. Interest-based and behavioral marketing.
  8. Contact requests and communication.
  9. Profiling (creation of user profiles).
  10. Remarketing.
  11. Reach measurement (e.g. access statistics, recognition of returning visitors).
  12. Security measures.
  13. Tracking (e.g. interest-/behavior-related profiling, use of cookies).
  14. Provision of contractual services and customer service.
  15. Administration and answering of inquiries.
  16. Target group formation (determination of target groups relevant for marketing purposes or other output of content).

4. Relevant legal bases

In the following, we share the legal bases 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, national data protection regulations may apply in your or our country of residence or domicile. If, furthermore, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  1. Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of personal data concerning them for a specific purpose or several specific purposes.
  2. Performance of a contract 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 a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  3. Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  4. Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
  5. Performance of a contract and pre-contractual inquiries (EKD) (§ 6 No. 5 DSG-EKD) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.

National data protection regulations in Germany:

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transfer and automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

5. 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, in order 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, disclosure, ensuring availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): We use SSL encryption to protect your data transmitted via our online offer. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

6. Transmission and disclosure of personal data

In the context of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organizational units or persons or 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 appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the group of companies:

We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of data is based on

7. 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 only takes place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, 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 ).

8. Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie primarily serves to store the information about a user during or after their visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. We also include other technologies that perform the same functions as cookies in the term cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

  1. Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their browser.
  2. Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users, which are used for reach measurement or for marketing purposes, can be stored in such a cookie.
  3. First-party cookies: First-party cookies are set by us.
  4. Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  5. Necessary cookies (also: essential or strictly necessary): Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  6. Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of reach measurement and when the interests of a user or their behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases:

The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the economic operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period:

Unless we provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume 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 possibility at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially explain your objection by means of the settings of your browser, 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 declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent:

We use a procedure for cookie consent management, within the framework of which the users’ consent to the use of cookies, or the processing and providers mentioned within the framework of the cookie consent management procedure, is obtained, managed and revoked by the users. The declaration of consent is stored in order not to have to repeat its query again and to be able to prove the consent in accordance with the legal obligation. The storage can take place 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 the consent can be up to two years. A pseudonymous user identifier is formed and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

  1. Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Users (e.g. website visitors, users of online services).
  3. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:

  1. Real Cookie Banner: To manage the cookies and similar technologies (tracking pixels, web beacons, etc.) used and related consents, we employ the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/. Legal bases for the processing of personal data in this context are Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents. The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.

9. Commercial and business services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.

We process these data to fulfill our contractual obligations, to safeguard our rights, and for the purposes of the administrative tasks associated with this information, as well as for corporate organization. We only pass on the data of the contractual partners to third parties within the framework of applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations, or if the data subjects have given their consent (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 scope of this data protection declaration.

We inform the contractual partners which data are required for the aforementioned purposes before or during data collection, e.g., in online forms, through special markings (e.g., colors) 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., generally after a period of 4 years, unless the data are stored in a customer account, e.g., as long as they must be retained for archiving for legal reasons (e.g., for tax purposes, generally 10 years). We delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.

Economic analyses and market research:

For business management reasons and in order to be able to recognize market trends, wishes of the contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of data subjects.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g., to determine customer groups with different characteristics). We may take into account the profiles of registered users, including their details, e.g., on services used, if available. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Agency services:

We process the data of our customers within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services.

Artistic and literary services:

We process the data of our clients in order to enable them to select, acquire or commission the selected services or works and related activities, as well as their payment and delivery or execution or provision.

The required information is marked as such within the scope of the order, order or comparable contract conclusion and includes the information required for delivery and billing as well as contact information in order to be able to hold any consultations.

  1. Processed data types: 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).
  2. Data subjects: Interested parties, business and contractual partners, customers.
  3. Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to inquiries, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavioral marketing, profiling (creation of user profiles).
  4. Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

10. Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we make use of 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 make use of 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 the provision of the hosting offer may include all information relating to the users of our online offer that is incurred in the context of use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting:

The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the participating providers) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. We ask you to note that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are 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 can therefore not assume any responsibility for the transmission path of e-mails 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 may include the address and name of the accessed web pages and files, date and time of access, data volumes 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 utilization of the servers and their stability.

  1. Processed data types: 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).
  2. Data subjects: Users (e.g. website visitors, users of online services).
  3. Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

11. Special notes on applications (apps)

We process the data of the users of our application to the extent that this is necessary to provide the users with the application and its functionalities, to monitor its security and to be able to further develop it. We may also contact users in compliance with the statutory requirements if the communication is necessary for the purposes of administration or use of the application. Otherwise, we refer to the data protection notices in this data protection declaration with regard to the processing of the data of the users.

Legal bases:

The processing of data that is necessary for the provision of the functionalities of the application serves the fulfillment of contractual obligations. This also applies if the provision of the functions requires authorization from the users (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it takes place on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the processing of the data covered by the consent takes place on the basis of the consent.

Device permissions for access to functions and data:

The use of our application or its functionalities may require permissions from users for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by the users and can be changed at any time in the settings of the

  1. Processed data types: Inventory data (e.g., names, addresses), meta/communication data (e.g., device information, IP addresses).
  2. Purposes of processing: Provision of contractual services and customer service.
  3. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

12. Contacting us

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information of the requesting persons is processed, insofar as this is necessary to answer the contact requests and any requested measures.

The answering of contact requests within the scope of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  1. Processed data types: 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. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Communication partners.
  3. Purposes of processing: Contact requests and communication.
  4. Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

13. Video conferences, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “third-party providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions, as well as entries in chats and shared screen content.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal bases:

If we ask users for their consent to the use of third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis for the processing is the consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the data of the users are processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.

  1. Processed data types: 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. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Communication partners, users (e.g., website visitors, users of online services).
  3. Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, direct marketing (e.g., by e-mail or postal mail).
  4. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:

  1. GoToMeeting: Conference software; Service provider: LogMeIn Ireland Limited, Bloodstone Building Block C 70, Sir John Rogerson’s Quay Dublin 2, Ireland, Parent company: LogMeIn, Inc., 320 Summer Street, Boston, MA 02210 320 Summer Street Boston, Massachusetts 02210, USA; Website: https://www.gotomeeting.com/de-de; Data protection declaration: https://www.logmeininc.com/de/legal/privacy.
  2. Microsoft Teams: Messenger and conference software; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.com; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.
  3. Skype: Messenger and conference software; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://www.skype.com/de/; Data protection declaration: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.
  4. TeamViewer: Conference software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Website: https://www.teamviewer.com/de; Data protection declaration: https://www.teamviewer.com/de/datenschutzerklaerung/.
  5. Whereby: Video conferences, web conferences and webinars; Service provider: Video Communication Services AS, Gate 1 no. 101, 6700 Måløy, Norway; Website: https://whereby.com/; Data protection declaration: https://whereby.com/information/tos/privacy-policy/; Standard contractual clauses (guarantee of data protection level for processing in third countries): Are part of the contractual relationship as part of the terms and conditions.
  6. Zoom: Video conferences, web conferences and webinars; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Data protection declaration: https://zoom.us/docs/de-de/privacy-and-legal.html; Standard contractual clauses (guarantee of data protection level for processing in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (Referred to as Global DPA).

14. Newsletter and electronic notifications

We only send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described within the scope of a registration for the newsletter, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient if you provide your e-mail 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:

The registration for our newsletter takes place in principle in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail 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. Likewise, the changes to your data stored with the dispatch service provider are logged.

Deletion and restriction of processing:

We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a formerly given consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the storage of the e-mail address for this purpose alone in a blocklist (so-called “blocklist”).

The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving its proper execution. If we commission a service provider with the dispatch of e-mails, this takes place on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal bases:

Newsletters are sent based on the consent of the recipients or, if consent is not required, based on our legitimate interests in direct marketing, provided and to the extent permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process 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 measurement:

The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from its 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, 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 retrieval 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 intention nor, if used, that of the shipping service provider to observe individual users. Rather, the evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the performance measurement take place, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system, which serves both our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to.

  1. Processed data types: 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).
  2. Data subjects: Communication partners.
  3. Purposes of processing: Direct marketing (e.g. by e-mail or post).
  4. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  5. 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 contact options listed above, preferably e-mail.

Used services and service providers:

  1. Mailchimp: E-mail marketing platform; Service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Data protection declaration: https://mailchimp.com/legal/privacy/.
  2. Zapier: Import of e-mail addresses to the shipping service providers used from other platforms or other sources; Service provider: Zapier, Inc., 548 Market St #62411, San Francisco, California 94104, USA; Website: https://zapier.com; Data protection declaration: https://zapier.com/privacy.
  3. Brevo: E-mail marketing platform; Service provider: Brevo – Sendinblue, 7 rue de Madrid, 75008 Paris, France; Website: https://brevo.com; Data protection declaration: https://www.brevo.com/legal/privacypolicy/.

15. Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke their consent at any time or to object to advertising communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. The processing of this data is limited to the purpose of defending against possible claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  1. Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  2. Data subjects: Communication partners.
  3. Purposes of processing: Direct marketing (e.g. by e-mail or post).
  4. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

16. Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) is used to evaluate the visitor flows of our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas need optimization.

In addition to web analysis, we can also use testing methods to test and optimize different versions of our online offer or its components, for example.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, viewed content, 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 data 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. pseudonymization by shortening the IP address) to protect the users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope 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 procedures.

Notes on legal bases:

If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of users will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  1. Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Users (e.g. website visitors, users of online services).
  3. Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-/behavior-related profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  4. Security measures: IP masking (pseudonymization of the IP address).
  5. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:

  1. 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/; Data protection declaration: https://policies.google.com/privacy.
  2. Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags via an interface and integrate other services into our online offering (reference is made to further information in this privacy policy). 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 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.

17. 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 relevant to the presentation of the aforementioned content is stored about the user. This information may include, for example, viewed content, 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 data may also be processed.

The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect the users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of the online marketing procedure, but rather pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purposes of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network connects the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

We generally only receive access to summarized information about the success of our advertisements. However, within the scope of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. e.g. to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that the cookies used are stored for a period of two years.

Notes on legal bases:

If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of users will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Facebook pixel and target group formation (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), Facebook is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to display the Facebook Ads placed by us only to those users on Facebook and within the services of the 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 that can be seen on the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we would also like to ensure that our Facebook Ads correspond to the potential interests of the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of 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”).

Together with Facebook Ireland Ltd., we are jointly responsible for the collection or receipt within the scope of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook pixel and comparable functions (e.g. interfaces) that are executed on our online offer or receives within the scope of a transmission for the following purposes: a) Display of content advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g. improvement of the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook (“Addition for Controllers”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous for us), then this processing does not take place within the scope 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 to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.

  1. Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers).
  2. Data subjects: Users (e.g. website visitors, users of online services), prospective customers, customers.
  3. Purposes of processing: Tracking (e.g. interest-/behavior-related profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), interest-based and behavior-related marketing, profiling (creation of user profiles), reach measurement (e.g. access statistics, recognition of returning visitors), contact requests and communication, direct marketing (e.g. by e-mail or post), target group formation, administration and answering of inquiries, target group formation (determination of target groups relevant for marketing purposes or other output of content).
  4. Security measures: IP masking (pseudonymization of the IP address).
  5. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  6. Possibility of objection (opt-out): We refer to the data protection information of the respective providers and the objection options (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, there is the possibility that you can deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary form 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) Across regions: https://optout.aboutads.info.

Used services and service providers:

  1. Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags via an interface and integrate other services into our online offering (reference is made to further information in this privacy policy). 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 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.
  2. Google Analytics: Online marketing 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; 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.
  3. Google Ads and conversion measurement: We use the online marketing method “Google Ads” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, 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 with a “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.
  4. 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 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 correspond to their interests. If a user is shown ads for products that they have been interested in on other online offers, 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.
  5. Pinterest Web Analytics: Online marketing and web analytics; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://analytics.pinterest.com/; Privacy policy: https://about.pinterest.com/de/privacy-policy.
  6. Pipedrive: Cloud-based software for organizing and optimizing our customer and partner relationships and for managing incoming emails and information requests; Service provider: Pipedrive OÜ, Paldiski mnt 80, Tallinn 10617, Estonia; Website: https://www.pipedrive.com/de; Privacy policy: https://www.pipedrive.com/de/privacy.
  7. TikTok Pixel: A TikTok pixel is a snippet of HTML code that is loaded when a user visits a website. When a user comes to our online offer, the pixel is triggered and tracks the user’s behavior and conversions (possible uses: measurement of campaign performance, optimization of ad delivery, building of custom and similar target groups); Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://ads.tiktok.com/help/article?aid=6669727593823993861; Privacy policy: https://www.tiktok.com/de/privacy-policy.

18. 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 area of the European Union. This may result in risks for users, because, for example, the enforcement of users’ rights could be made more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on the usage behavior and resulting interests of users. The usage profiles can in turn be used to display advertisements within and outside the networks that are likely to correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (in particular 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 opt-out options, we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

Facebook:

Together with Facebook Ireland Ltd., we are responsible for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content that 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 users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy statement: 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, so-called “Page Insights”, for 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 special agreement with Facebook (“Information about Page Insights”, 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 fulfill the rights of data subjects (i.e. users can, for example, send requests for information or deletion 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 about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data).

  1. Processed data types: 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. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Users (e.g. website visitors, users of online services).
  3. 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), profiling (creation of user profiles).
  4. Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Used services and service providers:

  1. Instagram: Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  2. Facebook: Social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out option: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
  3. 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; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  4. Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com; Privacy policy: https://about.pinterest.com/de/privacy-policy; Opt-out option: https://about.pinterest.com/de/privacy-policy.
  5. TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/de/privacy-policy.
  6. Vimeo: Social network and video platform; 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.
  7. YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated.

19. Plugins and embedded functions and content

We integrate function 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 may 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 users, as they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and the operating system, referring websites, the time of the visit and other information on the use of our online offer, as well as be linked to such information from other sources.

Notes on legal bases:

If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of users will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Facebook plugins and content:

Together with Facebook Ireland Ltd., we are jointly responsible for the collection or receipt within the framework of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook social plugins (and embedding functions for content) that are executed on our online offer, or receives within the framework of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g. improvement of the recognition of which content or advertising information presumably corresponds to the interests of the users). We have entered into a special agreement with Facebook (“Controller Addendum”, 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 fulfill the rights of data subjects (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous for us), this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (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.

Instagram plugins and content:

Together with Facebook Ireland Ltd., we are jointly responsible for the collection or receipt within the framework of a transmission (but not the further processing) of “event data” that Facebook collects by means of functions of Instagram (e.g. embedding functions for content) that are executed on our online offer, or receives within the framework of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g. improvement of the recognition of which content or advertising information presumably corresponds to the interests of the users). We have entered into a special agreement with Facebook (“Controller Addendum”, 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 fulfill the rights of data subjects (i.e. users can, for example, send requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous for us), this processing does not take place within the framework of joint responsibility, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (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.

  1. Processed data types: Usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) (“Event data” is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or in other ways) and relates to people or their actions; The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from it with the deletion of our Facebook account), location data (information on the geographical position of a device or a person), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), inventory data (e.g. names, addresses).
  2. Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  3. Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, direct marketing (e.g. by e-mail or post), 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 answering of inquiries.
  4. Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR).

Used services and service providers:

  1. Facebook Plugins and Content: Facebook Social Plugins and content – This may include content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out option: Ad settings: https://www.facebook.com/settings?tab=ads.
  2. Font Awesome: Display of fonts and symbols; Service provider: Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy policy: https://fontawesome.com/privacy.
  3. Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation 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.
  4. Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually 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; 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.
  5. Instagram Plugins and Content: Instagram Plugins and content – This may include content such as images, videos or texts and buttons with which users can share content from this online offer within Instagram. Service provider: https://www.instagram.com, Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  6. LinkedIn Plugins and Content: LinkedIn plugins and content – This may include content such as images, videos or texts and buttons with which users can share content from this online offer within LinkedIn. 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; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  7. MyFonts: Fonts; data processed as part of the font retrieval include the identification number of the web font project (anonymized), the URL of the licensed website, which is linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Website: https://www.myfonts.co; Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
  8. Typekit fonts from Adobe: We integrate the fonts (“Typekit fonts”) of the provider Adobe, whereby the data of the users are used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service provider: Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland; Website: https://www.adobe.com/de; Privacy policy: https://www.adobe.com/de/privacy.html.
  9. 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.
  10. Xing Plugins and Buttons: Xing plugins and buttons – This may include content such as images, videos or texts and buttons with which users can share content from this online offer within Xing. Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

20. Planning, organization and auxiliary tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting the third-party providers and their services, we observe the statutory requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, to optimize the service or for marketing purposes. We therefore ask that you observe the data protection notices of the respective third-party providers.

Notes on legal bases:

If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the data of the users will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  1. Processed data types: 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. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  2. Data subjects: Communication partners, users (e.g. website visitors, users of online services), customers.
  3. Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-/behavior-related profiling, use of cookies), profiling (creation of user profiles), contact requests and communication, conversion measurement (measurement of the effectiveness of marketing measures), target group formation, administration and answering of inquiries, feedback (e.g. collection of feedback via online form), target group formation (determination of target groups relevant for marketing purposes or other output of content), office and organizational procedures.
  4. Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR), fulfillment of contract and pre-contractual inquiries (EKD) (§ 6 No. 5 DSG-EKD).

Used services and service providers:

  1. Bitly: URL shortening service and link management platform; Service provider: Bitly, Inc., 139 Fifth Avenue, 5th Floor, New York, NY 10010, USA; Website: https://bitly.com; Privacy policy: https://bitly.com/pages/privacy.
  2. HubSpot: Social media publishing, reporting (e.g. traffic sources, access numbers, web analysis), contact management (e.g. contact forms, direct communication and user segmentation), landing pages; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Website: https://www.hubspot.de; Privacy policy: https://legal.hubspot.com/de/privacy-policy.
  3. Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Website: https://miro.com/; Privacy policy: https://miro.com/legal/privacy-policy/.
  4. Trello: Project management tool; Service provider: Trello Inc., 55 Broadway New York, NY 10006, USA, Parent company: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Website: https://trello.com/; Privacy policy: https://trello.com/privacy.
  5. WeTransfer: Transfer of files via the Internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Website: https://wetransfer.com; Privacy policy: https://wetransfer.com/legal/privacy.

21. Deletion of data

The data processed by us will be deleted in accordance with the statutory requirements as soon as the consents to processing granted are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be 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 reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

22. Amendment and update of the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as the changes to 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.

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 please check the information before contacting us.

23. Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  1. Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  2. Right of revocation in the case of consent: You have the right to revoke consents granted at any time.
  3. Right of access: You have the right to request confirmation as to whether data concerning you are being processed and to access to this data and to further information and a copy of the data in accordance with the statutory requirements.
  4. Right to rectification: In accordance with the statutory requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
  5. Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to demand that data concerning you be erased without delay or, alternatively, to demand a restriction of the processing of the data in accordance with the statutory requirements.
  6. Right to data portability: You have the right, in accordance with the statutory requirements, to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format or to request its transfer to another controller.
  7. Complaint to a supervisory authority: Furthermore, in accordance with the statutory requirements, you have the right 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 relating to you infringes the GDPR.

24. Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to serve understanding. The terms are sorted alphabetically.

  1. Cross-Device Tracking: Cross-device tracking is a form of tracking in which behavioral and interest information of users is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g. mobile phones or desktop computers). The online identifier is not linked to clear data, such as names, postal addresses or e-mail addresses, for most providers.
  2. IP Masking: “IP masking” refers to a method in which the last octet, i.e. the last two digits 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 pseudonymizing processing methods, especially in online marketing.
  3. Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when potential interests of users in advertisements and other content are determined as accurately as possible. This is done on the basis of information on their prior 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.
  4. Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the devices of users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can use this to track whether the ads we place on other websites were successful.
  5. 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.
  6. Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) or to predict them (e.g. interests in certain content or products, click behavior on a website or the location). Cookies and web beacons are often used for profiling purposes.
  7. Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and may include the behavior or interests of visitors in certain information, such as 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 allows 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 accurate analyses of the use of an online offer.
  8. Remarketing: “Remarketing” or “retargeting” refers to the practice of noting, for advertising purposes, which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
  9. 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 means and functions of location determination. Location data is used to indicate the geographically determinable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
  10. Tracking: “Tracking” refers to the ability to trace the behavior of users across multiple online services. As a rule, behavioral and interest information relating to the online services used is stored in cookies or on the 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.
  11. Controller: The term “controller” refers to 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.
  12. Processing: “Processing” means 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.
  13. Target group formation: Target group formation (or “Custom Audiences”) refers to the determination of target groups for advertising purposes, e.g. the display of advertisements. For example, the interest of a user in certain products or topics on the Internet can be used to infer 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) refers to the practice of displaying content deemed suitable to users whose profiles or interests are presumed to correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.

Created with the Datenschutz-Generator.de by Dr. Thomas Schwenke

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