Privacy Policy
Introduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, 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: 4 May 2022
Table of contents
Introduction
Responsible
Overview of processing operations
Relevant legal basis
Security measures
Transfer of personal data
Data processing in third countries
Deletion of data
Use of cookies
Business services
Provision of online services and web hosting
Blogs and publication media
Contact and enquiry management
Communication via messenger
Video conferencing, online meetings, webinars and screen sharing
Newsletter and electronic notifications
Web analysis, monitoring and optimisation
Online marketing
Presence in social networks (social media)
Plugins and embedded functions and content
Amendment and updating of the privacy policy
Rights of data subjects
Definitions
Responsible
LaHaye, Kimberly
Auf Penaten 44
53604 Bad Honnef
Germany
Authorised representatives:
Kimberly Lahaye
E-mail address:
info@kimlahaye.com
Phone:
+491741752571
Imprint:
https://kimlahaye.com/impressum
Overview of the processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Inventory data.
Payment data.
Contact data.
Content data.
Contract data.
Usage data.
Meta/communication data.
Event data (Facebook).
Special categories of data
Health data.
Sex life or sexual orientation data.
Religious or ideological beliefs.
Data revealing racial or ethnic origin.
Categories of data subjects
Customers.
Prospective customers.
Communication partners.
Users.
Business and contractual partners.
Purposes of processing
Provision of contractual services and customer service.
Contact requests and communication.
Security measures.
Direct marketing.
Reach measurement.
Office and organisational procedures.
Remarketing.
Conversion measurement.
Target group formation.
Query management and response.
Server monitoring and error detection.
Feedback.
Marketing.
Profiles with user-related information.
Target group formation.
Provision of our online offer and user friendliness.
Relevant legal bases
Below you will find an overview of the legal basis of the 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. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject's request.
Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO) - Processing is necessary to protect the vital interests of the data subject or another natural person.
Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Transmission of personal data
In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the statutory requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Data deletion
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Within the framework of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that applies specifically to the respective processing operations.
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.
Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. The purposes for which the cookies are processed by us are explained in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO (further information on the objection is provided within the scope of this data protection declaration). Users can also declare their objection using the settings of their browser.
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); server monitoring and error detection.
Weitere Hinweise zu Verarbeitungsprozessen, Verfahren und Diensten:
Further guidance on processing operations, procedures and services: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by the users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.
SquareSpace: Squarespace offers software as a service for the creation and hosting of websites; service provider: Squarespace, Inc. 8 Clarkson St, New York, NY 10014, USA; website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.squarespace.com/dpa.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.
We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Shop and E-Commerce
We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to consult with you if necessary.
Coaching
We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as "clients") in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
Within the scope of our activities, we may also process special categories of data, in this case in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. To this end, we obtain explicit consent from clients where necessary and otherwise process the special categories of data where this serves the health of the clients, the data is public or other legal permissions exist.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client's data to third parties or agents, such as public authorities, accounting offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law.
Online courses and training
We process the data of the participants of our online courses and online trainings (uniformly referred to as "participants") in order to be able to provide our course and training services to them. The data processed, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship. The data basically includes details of the courses and services used and, insofar as part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and the evaluation of our services as well as those of the course and training instructors.
Therapeutic services
We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as "clients") in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
Within the scope of our activities, we may also process special categories of data, in this case in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial and ethnic origin, political opinions, religious or ideological beliefs or trade union membership. To this end, we obtain explicit consent from clients where necessary and otherwise process the special categories of data where this serves the health of the clients, the data is public or other legal permissions exist.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client's data to third parties or agents, such as public authorities, medical institutions, laboratories, billing offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law.
Events and activities
We process the data of the participants of the events, functions and similar activities offered or organised by us (hereinafter uniformly referred to as "participants" and "events") in order to enable them to participate in the events and to make use of the services or activities associated with participation.
Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the scope of disclosure (e.g. in the case of thematically oriented events or serves health care, safety or is done with the consent of the persons concerned).
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we obtain access to information of the end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.
Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
Special categories of personal data: Health data (Art. 9(1) DGSVO); Data concerning sex life or sexual orientation (Art. 9(1) DGSVO); Religious or philosophical beliefs (Art. 9(1) DGSVO); Data revealing racial or ethnic origin.
Data subjects: Customers; prospective customers; business and contractual partners.
Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organisational procedures; administration and response to requests.
Legal grounds: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO).
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: provision of our online offer and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); server monitoring and error detection.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of the access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.The server log files may be used for security purposes, for example, to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure server utilisation and stability; deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.
SquareSpace: Squarespace offers software as a service for the creation and hosting of websites; service provider: Squarespace, Inc. 8 Clarkson St, New York, NY 10014, USA; website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.squarespace.com/dpa.
Blogs and publishing media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); security measures; managing and responding to requests.
Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO).
Further guidance on processing operations, procedures and services:
Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.Furthermore, we reserve the right, based on our legitimate interests, to process the information of the users for the purpose of spam detection.On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of the users for their duration and to use cookies to avoid multiple votes.The personal information provided in the context of comments and posts, any contact and website information as well as the content-related information will be stored permanently by us until the objection of the user.
DISQUS comment function: We use the DISQUS comment service based on our legitimate interests in efficient, secure and user-friendly comment management.To use the DISQUS comment function, users can register via their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). The user login data is obtained by DISQUS from the platforms. It is also possible to use the DISQUS comment function as a guest, without creating or using a user account with DISQUS or one of the specified social media providers.We merely embed DISQUS with its functions into our website, whereby we can influence the users' comments. However, users enter into a direct contractual relationship with DISQUS, under which DISQUS processes users' comments and is a contact for any deletion of users' data. We refer to the privacy policy of DISQUS and also point out to the users that they can assume that DISQUS will store their IP address and the time of the comment in addition to the comment content. Cookies may also be stored on users' computers and used to display advertising; service provider: DISQUS, Inc., 301 Howard St, Floor 3 San Francisco, California- 94105, USA; Website: https://disqus.com/; Privacy policy: https://help.disqus.com/terms-and-policies/disqus-privacy-policy; Opt-out: https://disqus.com/data-sharing-settings.
Contact and enquiry management
When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.
The answering of contact requests as well as the administration of contact and request data in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to answer (pre-)contractual requests and otherwise on the basis of the legitimate interests in answering the requests and maintaining user or business relationships.
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).
Data subjects: Communication partners.
Purposes of processing: contact requests and communication; provision of contractual services and customer service.
Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO).
Further guidance on processing operations, procedures and services:
Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context in order to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.
Communication via messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us in alternative ways, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we additionally point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, of their own accord, we use Messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke consent given and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.
Types of data processed: contact data (e.g. e-mail, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
Data subjects: Communication partners.
Purposes of processing: contact requests and communication; direct marketing (e.g. by e-mail or post).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
Apple iMessage: Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; website: https://www.apple.com/de/; privacy policy: https://www.apple.com/legal/privacy/de-ww/.
Instagram: Messaging via the social network Instagram; 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 Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger's end-to-end encryption requires activation if it should not be activated by default); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; order processing contract: https://www.facebook.com/legal/terms/dataprocessing; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
Microsoft Teams: Microsoft Teams - Messenger; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; Parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://products.office.com; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security notices: https://www.microsoft.com/de-de/trustcenter; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
Signal: Signal Messenger with end-to-end encryption; service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; website: https://signal.org/de; privacy policy: https://signal.org/legal/.
Skype: Skype Messenger with end-to-end encryption - Skype's end-to-end encryption requires it to be enabled (unless it should be enabled by default); Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://www.skype.com/de/; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter.
Slack: Instant messaging service; service provider: Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105, USA; Website: https://slack.com/intl/de-de/; Privacy policy: https://slack.com/intl/de-de/legal; Order processing contract: https://slack.com/intl/de-de/terms-of-service/data-processing; Standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://slack.com/intl/de-de/terms-of-service/data-processing; Further information: Security measures: https://slack.com/intl/de-de/security-practices.
Telegram Broadcasts: Telegram Broadcasts - Messenger with end-to-end encryption; Service provider: Telegram, Dubai; Website: https://telegram.org/; Privacy policy: https://telegram.org/privacy.
WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin 2, D02 KH28, Ireland; website: https://www.whatsapp.com/; privacy policy: https://www.whatsapp.com/legal.
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting the conferencing platforms and their services, we comply with the legal requirements.
Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends on the one hand on which data is requested in the context of a specific conference (e.g. provision of access data or clear names) and on the other hand on which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the participants' end devices, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of the communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent - if necessary.
Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms and select the optimal security and data protection settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g. by notifying fellow participants, locking doors and using the function to make the background unrecognisable, if technically possible). Links to the conference rooms as well as access data, may not be passed on to unauthorised third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in participant lists, in the case of processing of conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
Data subjects: Communication partners; users (e.g. website visitors, users of online services).
Purposes of processing: provision of contractual services and customer service; contact requests and communication; office and organisational procedures.
Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
Microsoft Teams: messenger and conferencing software; service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland; parent company: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://products.office.com; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security notices: https://www.microsoft.com/de-de/trustcenter; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA.
Zoom: video conferencing, web conferencing and webinars; service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Order Processing Agreement: https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA); Standard Contractual Clauses (ensuring level of data protection for processing in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Apart from that, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's 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. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former 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 e-mail address in a block list (so-called "block list") for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in efficient and secure dispatch. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.
Contents:
Information about us, our services, campaigns and offers.
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).
Data subjects: Communication partners.
Purposes of processing: direct marketing (e.g. by email or post); reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measurement of the effectiveness of marketing measures); server monitoring and error detection.
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Option to object (opt-out): You can cancel 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 given above, preferably e-mail, for this purpose.
Further guidance on processing operations, procedures and services:
Measurement of opening and click-through rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.The measurement of the opening rates and the click rates as well as the storage of the measurement results in the profiles of the users as well as their further processing are based on the consent 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. In this case, the stored profile information will be deleted.
SquareSpace: Squarespace offers software as a service for the creation and hosting of websites; service provider: Squarespace, Inc. 8 Clarkson St, New York, NY 10014, USA; website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy; standard contractual clauses (ensuring level of data protection in case of processing in third countries): https://www.squarespace.com/dpa.
Web analysis, monitoring and optimisation
Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creating user profiles); conversion measurement (measuring the effectiveness of marketing measures); server monitoring and error detection.
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
SquareSpace: Squarespace offers Software as a Service for the creation and hosting of websites; service provider: Squarespace, Inc. 8 Clarkson St, New York, NY 10014, USA; website: https://www.squarespace.com; privacy policy: https://www.squarespace.com/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.squarespace.com/dpa.
Onlinemarketing
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "content") based on the potential interests of users and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the information about the user relevant 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 and functions used. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Event data (Facebook) ("Event data" is data that may be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or other means), and relates to individuals 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 creating target groups for content and advertising information (Custom Audiences). Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), 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); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: remarketing; conversion measurement (measuring the effectiveness of marketing activities); targeting; audience building (determining target groups relevant for marketing purposes or otherwise outputting content); marketing; profiling with user-related information (creating user profiles).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the options for objection given to the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.
Further guidance on processing operations, procedures and services:
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), it is possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only 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 offer or who have certain characteristics (e.g. interest in certain topics or products that are evident 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 interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; standard contractual clauses (ensuring level of data protection for processing in third countries): The "Facebook EU Data Transfer Addendum" (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of commissioned processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the "Facebook Platform Terms of Use" (https://developers.facebook.com/terms) with regard to Facebook's own processing of event data in the context of ad placement; Further information: The "Data Processing Terms and Conditions" (https://www.facebook.com/legal/terms/dataprocessing/update) apply with regard to event data that Facebook processes on behalf to provide reporting and analysis to companies; Furthermore, the "Controller Addendum" applies as an agreement on joint responsibility (Art. 26 para. 1 sentence 3 of the GDPR), which is relevant in the case of the autonomous processing of event data by Facebook for the purposes of targeting as well as improving and securing Facebook products.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of information requests and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
Facebook pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights", to Page operators to provide them with insights into how people interact with their Pages and with the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard Contractual Clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.
LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; order processing agreement: https://legal.linkedin.com/dpa; standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://legal.linkedin.com/dpa; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
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; Further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/pinterest-advertising-services-agreement/.
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; opt-out: https://adssettings.google.com/authenticated.
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Notes on legal basis: 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, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); event data (Facebook) ("event data" is data that can be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or in other ways) and relates to persons or their actions; the data includes e.g. information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.). Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), 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).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: provision of our online offer and user-friendliness; provision of contractual services and customer service; profiles with user-related information (creation of user profiles); marketing.
Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO); Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Further guidance on processing operations, procedures and services:
Facebook plugins and content: Facebook social plugins and content - This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook. com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in connection with any transmission (but not the further processing) of "event data" collected or received by Facebook through the Facebook social plugins (and content embedding features) running on our website for the purposes of: a) displaying content and promotional information relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook social plugins) to users of our website. (c) improving ad delivery and personalising features and content (e.g., improving the identification of which content or advertising information is likely to be relevant to users' interests). We have entered into a specific agreement with Facebook ("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 fulfil the data subject rights (i.e. users can, for example, direct information or deletion requests to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), this processing is not carried out under shared responsibility but on the basis of a commissioned processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing) the "Data Security Terms and Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
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.
Google Fonts: Purchase of fonts ("Google Fonts") from the provider Google for the purpose of a technically secure, maintenance-free and efficient use of fonts with regard to topicality and loading times, their uniform presentation and consideration of possible restrictions under licensing law. Google is informed of the user's IP address so that Google can provide the fonts in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted which are necessary for the provision of the fonts depending on the devices used and the technical environment. ; 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 Fonts: Purchase of fonts ("Google Fonts") for the purpose of a user-friendly presentation of our online offer; service provider: The Google Fonts are hosted on our server, no data is transmitted to Google.
Google Maps: We integrate the maps of the "Google Maps" service of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context 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: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Instagram plugins and content: Instagram Plugins and Content - This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online service within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in connection with a transmission (but not the further processing) of "Event Data" that Facebook collects or receives in connection with a transmission through Instagram features (e.g., content embedding features) running on our Online Offer for the purposes of: a) displaying content and promotional information that is relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Instagram); c) providing commercial and transactional messages (e.g., targeting users via Instagram). (c) improving ad delivery and personalising features and content (e.g., improving the ability to identify which content or advertising information is likely to be of interest to users). We have entered into a specific 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 fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), this processing is not carried out under shared responsibility but on the basis of a commissioned processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing) the "Data Security Terms and Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
Twitter plugins and content: Twitter plugins and buttons - This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Twitter; Service Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent Company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; 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: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Ad display settings: 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: We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data use for marketing purposes (https://adssettings.google.com/).
Amendment and update of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please 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 Art. 15 to 21 GDPR:
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right of revocation for consents: You have the right to revoke any consent you have given at any time.
Right of access: You have the right to obtain confirmation as to whether data relating to you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the law.
Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
Complaint to supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
Conversion measurement: Conversion measurement (also referred to as "visit action evaluation") is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using such personal data to analyse, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
Remarketing: "Remarketing" or "retargeting" is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
Server monitoring and error detection: With the help of server monitoring and error detection, we ensure the availability and integrity of our online offer and use the processed data to technically optimise our online offer. Performance, utilisation and comparable technical values are processed, which provide information about the stability and any anomalies of our online offer. In the event of errors and anomalies, individual enquiries from the users of our online offering are recorded in order to identify and rectify sources of problems.
Controller: "Controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
Target group formation: We speak of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where he or she viewed the products. In turn, we speak of "lookalike audiences" (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.