Privacy Policy
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both within the framework 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”).
Updated: April 20, 2021
Overview of processing operations
Types of data processed
Categories of data subjects
Purposes of processing
Applicable legal bases
- Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR) – The data subject has given his consent to the processing of his personal data for one or more specific purposes.
- Contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 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.
- Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. GDPR) – The processing is necessary to fulfil a legal obligation to which the controller is subject.
- Protection of vital interests (Art. 6 Abs. 1 S. 1 lit. d. GDPR) – Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
- Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR) – Processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.
Data protection and security measures
We shall take appropriate technical and organisational measures in accordance with the statutory requirements, taking into account the state of the art, the implementation costs and the nature, extent, 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.
Such measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, transmission, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and responses to data threats. 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): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Use of cookies
As a rule, cookies are also used if a user’s interests or behaviour (e.g. viewing of certain content, use of functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
If we use cookies or tracking technologies, we will inform you separately in our privacy policy.
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 your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Revocation and objection (opt-out): Irrespective of whether the processing is based on consent or legal permission, you have the option at any time to revoke a consent given or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”).
You can initially revoke the use of cookies using your browser settings, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online service). An objection to the use of cookies for the purposes of online marketing can be explained by means of a variety of services, above all in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info.
Processing Cookie Data on the Basis of Consent: Before we process or have processed data within the framework of the use of cookies, we ask the user for consent that can be revoked at any time. Before the consent has not been given, we may use cookies that are necessary for the operation of our online service. Their use is based on our interest and the user’s interest in the expected functionality of our online service.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.
We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organisation. Within the framework of applicable law, we only pass on the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of statutory obligations or is carried out with the consent of the contractual partners (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
Which data are necessary for the aforementioned purposes, we inform the contractual partners before or in the context of the data collection, e.g. in on-line forms, by special marking (e.g. colors) and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e., in principle after expiry of 4 years, unless the data is stored in a customer account, e.g., as long as they must be kept for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data disclosed to us by the contractual partner within the scope of an order will be deleted in accordance with the specifications of the order, in principle after the end of the order.
If 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.
User account: Contracting parties can create an account within our online offer (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, the contractual partners will be informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration as well as subsequent registrations and uses of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove registration and prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to retention, which is required for legal reasons. It is the responsibility of the customer to secure their data in the event of termination of the customer account.
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 related services, as well as their payment and delivery, or execution.
The required details are identified as such within the framework of the ordering or comparable purchase process and include the details required for delivery or provision and invoicing as well as contact information in order to be able to hold any consultation.
Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as “trainees”) in order to be able to provide them with our training services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance evaluation and the evaluation of our services as well as those of the teachers.
As part of our activities, we may also process special categories of data. If necessary, we obtain the express consent of the trainees for this purpose and otherwise process the special categories of data only if it is necessary for the provision of training services, for purposes of health care, social protection or the protection of vital interests of the trainees.
Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the trainees, we disclose or transfer the data of the trainees to third parties or agents, such as public authorities or in the field of IT, office or comparable services, in compliance with the provisions of professional law.
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 them with our services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
In the course of our activities, we may also process special categories of data, in particular information relating to the health of clients, their sex life or sexual orientation, if any, and data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. For this purpose we obtain, if necessary, the express consent of the clients and process the special categories of data otherwise if this serves the health of the clients, the data are public or other legal permissions exist.
Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, accounting offices and in the IT, office or comparable services sector, in compliance with the provisions of professional law.
Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.
Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, taking into account the professional requirements.
Events: We process the data of the participants of the events, events and similar activities offered or organized 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 actions associated with their participation.
Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the framework of disclosure (e.g. at thematically oriented events or serves health care, security or is done with the consent of those affected).
The required information is identified as such within the framework of the conclusion of the order, order or comparable contract 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 gain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.
- 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 of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Interested parties, business and contractual partners, customers.
- Purposes of processing: contractual services, contact requests and communication, office and organisational procedures, management and response to requests, security measures.
- Legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legal obligation (Art. 6 Abs. 1 S. 1 lit. c. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Use of online marketplaces for e-commerce
- 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 of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Customers.
- Purposes of processing: Contractual services and service.
- Legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
- Amazon: Online marketplace for e-commerce; service provider: Amazon Payments Europe S.C.A. 38 Avenue J.F. Kennedy, L-1855 Luxembourg; Website: https://www.amazon.de/; Privacy Policy: https://www.amazon.de/gp/help/customer/display?nodeId=3312401
- eBay: Online marketplace for e-commerce; service provider: eBay Marketplaces GmbH, Helvetiastrasse 15/17, 3005 Bern, Switzerland; Website: https://www.ebay.de/; Privacy Policy: https://www.ebay.de/help/policies/member-behavior-policies/datenschutzerklrung?id=4260.
- Rakuten: Online marketplace for e-commerce; service provider: Rakuten Deutschland GmbH, Geisfelder Str. 16, 96050 Bamberg, Germany; Website: https://www.rakuten.de/; Privacy Policy: https://www.rakuten.de/info/datenschutz.
Payment service provider
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient details. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.
For payment transactions, the terms and conditions and the data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other rights affected.
- Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject of contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Customers, interested parties.
- Purposes of processing: Contractual services and service.
- Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
- PayPal: Payment Services; Service Provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/; Privacy Policy: https://www.paypal.com/webapps/mpp/ua/privacy-full.
- Stripe: Payment services; Service provider: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA; Website: https://stripe.com; Privacy Policy: https://stripe.com/privacy.
Registration and Login
Users can create a user account. During the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
Users may be informed by e-mail about processes relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
When using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in a protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: contractual services and service, security measures, management and response to inquiries.
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR), Contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Reader data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the framework of this data protection notice.
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, if someone leaves illegal content (insults, forbidden political propaganda etc.) in comments and contributions. In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store the IP addresses of users for the duration of surveys and to use cookies to avoid multiple votes.
The personal information provided in the course of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.
Akismet Anti-Spam-Check: We use the “Akismet” service on the basis of our legitimate interests. Akismet is used to distinguish real people’s comments from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used, the computer system and the time of the entry.
Users are welcome to use pseudonyms or to refrain from entering their name or email address. They can completely prevent the transmission of data by not using our comment system. That would be a pity, but unfortunately we do not see any alternatives that work just as effectively.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), 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: contractual services, feedback (e.g. collection of feedback via online form), security measures, administration and response to inquiries.
- Legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR), Consent(Art. 6 Abs. 1 S. 1 lit. a GDPR), Protection of vital interests (Art. 6 Abs. 1 S. 1 lit. d. GDPR).
- Akismet Anti-Spam-Check: Akismet Anti-Spam-Check; Service provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
Contact
Contact enquiries within the framework of contractual or pre-contractual relationships are answered in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of legitimate interests in answering the enquiries.
Chat-Function: We offer a chat function within our online offer for purposes of communication and answering inquiries. The input of the users within the chat is processed for the purpose of answering their inquiries.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners, interested parties.
- Purposes of processing: contact requests and communication, management and response to requests.
- Legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 Abs. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Communication via Messenger
We use Messenger services for communication purposes and therefore ask you to observe the following information on the functionality of Messengers, on encryption, on the use of the metadata of communication and on the possibilities for objection.
You can also contact us by alternative means, e.g. by 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 attachments) is encrypted from end to end. This means that the content of the messages is not visible, not even by the messenger providers themselves. You should always use a current version of Messenger with encryption enabled to ensure that message content is encrypted.
However, we would like to draw the attention of our communication partners to the fact that although the providers of the messengers do not view the content, they can find out that and when communication partners communicate with us as well as technical information about the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal bases: If we request permission from communication partners before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use Messenger in our dealings with our contractual partners and as part of the 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 for communication via Messengers. We would also like to point out that we will not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time 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., 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 back to a previous conversation is to be expected and there are no legal obligations to retain data to prevent deletion.
Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right, for reasons of your safety, not to answer inquiries about Messenger. This is the case if, for example, internal contractual matters require special secrecy or if an answer via Messenger does not meet the formal requirements. In such cases we refer you to more adequate communication channels.
- Processed data types: 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).
- Data subjects: communication partners.
- Purposes of processing: contact enquiries and communication, direct marketing (e.g. by e-mail or post).
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
- Facebook-Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger end-to-end encryption requires activation unless activated by default); service providers: https://www.facebook.com, 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; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: https://www.facebook.com/settings?tab=ads.
- WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Inc. WhatsApp Legal 1601 Willow Road Menlo Park, California 94025, USA; Web site: https://www.whatsapp.com/; Privacy Statement: https://www.whatsapp.com/legal; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TSnwAAG&status=Active.
Provision of online services and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the framework of the provision of the hosting service may include all information relating to the users of our online service that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). Therefore, we cannot 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 each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the 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 for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
- Processed data types: Content data (e.g. text input, photographs, videos), 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).
- Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Newsletter and broad communication
We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient for you to enter your e-mail address. However, we may ask you to provide a name for the purpose of addressing us personally in the newsletter, or other information, if this is required for the purposes of the newsletter.
Double-Opt-In process: The registration to our newsletter takes place in principle in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after your registration in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise the changes of your data stored with the Versanddienstleister are logged.
Deletion and limitation of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address solely for this purpose in a blacklist.
The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving its proper course. If we hire a service provider to send e-mails, we do so on the basis of our legitimate interests in an efficient and secure delivery system.
Notes on legal bases: The newsletter is sent on the basis of the recipient’s consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent permitted by law, e.g. in the case of existing customer advertising. 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 to prove that it was conducted in accordance with the law.
Content: Information about us, our services, promotions and offers.
Impact measures: The newsletters contain a so-called “web-beacon”, i.e. a file the size of a pixel, which is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are first collected.
This information is used for the technical improvement of our newsletter on the basis of technical data or 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 access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, 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 evaluation of the newsletter and the performance measurement are carried out, 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 the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled or contradicted.
- 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).
- Data subjects: Communication partners.
- Purposes of processing: direct marketing (e.g. by e-mail or post).
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
- Objection possibility (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
- Mailchimp: Email marketing platform; service provider: Mailchimp – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Web Site: https://mailchimp.com; Privacy Statement: https://mailchimp.com/legal/privacy/; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Onlinemarketing
We process personal data for the purposes of online marketing, which includes in particular 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 user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, the online marketing process does not store any user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be used on other websites that use the same online marketing process, read out and analyzed for content presentation purposes and supplemented with further data and stored on the server of the online marketing process provider.
Exceptionally, plain 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 process we use and the network links the profiles of the users in the aforementioned information. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
As a matter of 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. to the conclusion of a contract with us, for example. The conversion measurement is used solely to analyze the success of our marketing measures.
Information 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, user data will be 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 draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: 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), interested parties.
- Purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, evaluation of visitation campaigns, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), measurement of reach (e.g. access statistics, recognition of returning visitors).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a GDPR), Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
- Opt-out: We refer you to the data protection information of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: http://optout.aboutads.info.
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage website tags through a single interface (including Google Analytics and other Google marketing services into our online offerings). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, reference is made to the following information on Google services. 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 Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- 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 Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-Out: Opt-Out-Plugin: http://tools.google.com/dlpage/gaoptout?hl=de; Advertising Display Settings: https://adssettings.google.com/authenticated.
Presence in social networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users, as it could, for example, make it more difficult to enforce the rights of users. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that by doing so they undertake to comply with EU data protection standards.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The usage profiles can also be used, for example, to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
We also point out that in the case of requests for information and the assertion of rights of data subjects, 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 need help, you can contact us.
- Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), 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 enquiries and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).
- Legal bases: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f. GDPR).
Services and service providers used:
- Instagram : Social Network; Service Provider: Instagram Inc. 1601 Willow Road, Menlo Park, CA, 94025, USA; Web site: https://www.instagram.com; Privacy Statement: http://instagram.com/about/legal/privacy.
- 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 Statement: https://www.facebook.com/about/privacy; Opt-Out: Settings for Advertisements: https://www.facebook.com/settings?tab=ads; Additional Privacy Notice: Agreement on Joint Processing of Personal Data on Facebook Pages: https://www.facebook.com/legal/terms/page_controller_addendum; Privacy Notice for Facebook Pages: 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 Statement: https://www.linkedin.com/legal/privacy-policy; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: social network; service provider: Twitter Inc. 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Statement: https://twitter.com/de/privacy, (settings) https://twitter.com/personalization.
- YouTube: Social network; 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 Statement: https://policies.google.com/privacy.
- Xing: social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
Modification and updating of the data protection declaration
Rights of data subjects
- Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right at any time to object to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct advertising.
- Right of revocation for consents: You have the right to revoke consents given at any time.
- Right of access: You have the right to obtain confirmation as to whether the data in question will be processed and to obtain access to such data, as well as further information and a copy of the data in accordance with the provisions of the law.
- Right of rectification: You have the right, in accordance with the law, to request the completion of data concerning you or the rectification of incorrect data concerning you.
- Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be deleted immediately or, alternatively, to demand a limitation of data processing in accordance with the statutory provisions.
- Right to data transfer: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible person.
- Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, to complain to a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged infringement was committed, if you are of the opinion that the processing of your personal data violates the GDPR.
Definitions of terms
This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
- Visit Promotion Evaluation: “Conversion Tracking” refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, we can track whether the ads we placed on other websites were successful.
- IP masking: “IP masking” is a method by 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. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing.
- Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is defined as the process by which potential interests of users in ads and other content are determined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting certain websites and staying on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, this enables us to track whether the ads we placed on other websites were successful.
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is any person who, directly or indirectly, in particular by attribution to an identifier such as a name, an identification number, location data, an online identifier (e.g. a name, a telephone number, a telephone number, an e-mail address, a telephone number, a fax number, a telephone number, a fax number, etc.), is identified as a natural person.B. cookie) or to one or more specific characteristics that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
- Profiling: “Profiling” means any automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to an individual (including, depending on the type of profiling, information relating to age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people).For example, interests in certain content or products, click behaviour on a website, or whereabouts.) Cookies and web beacons are often used for profiling purposes.
- Range measurement: Range measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and may include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can recognize, 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 purposes of range analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: “Remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes which products a user has been interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: “Tracking” is the term used when the behaviour of users can be traced across several online offers. As a rule, with regard to the online offers used, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Responsible: “Responsible” means the natural or legal person, public authority, agency or other body that alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation carried out with or without the aid of automated procedures or any such series of operations relating to personal data. The term is broad and covers virtually every handling of data, be it collection, analysis, storage, transmission or deletion.