data protection
WHAT IS IT ABOUT?
With the following data protection declaration, we would like to inform you about which types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
In the following chapters we will provide you with information about:
1st responsible person
2nd Contact Data Protection Officer
3. Relevant legal bases
4th Overview of processing
5th security measures
6th transmission of personal data
7th International data transfers
8th deletion of data
9th rights of the data subjects
10th use of cookies
11th Business Services
12th payment methods
13th provision of the online offer and web hosting
14th Registration, login and user account
15th blogs and publication media
16th contact and inquiry management
17th newsletters and electronic notifications
18th Advertising communication via email, post, fax or telephone
19th web analysis, monitoring and optimization
20th online marketing
21st Change and update of the privacy policy
1st RESPONSIBLE PERSON
CWS Hygiene Deutschland GmbH & Co KG
Dreieich Plaza 1a
63303 Dreieich, Germany
Phone: +49 (0)6103 309 30 93
E-mail: info@cws.com
Imprint: Management: Gatien Gillion Alex van Denderen Company headquarters: Dreieich District Court: AG Offenbach Commercial Register No.: HRB 52853 VAT ID No.: DE329163587
2nd CONTACT DATA PROTECTION OFFICER
CWS Hygiene Deutschland GmbH & Co KG
Data Protection Officer:
Dreieich Plaza 1a
63303 Dreieich, Germany
Email: data protection officer@cws.com
3. RELEVANT LEGAL BASIS
Relevant legal bases under the GDPR : Below you will find an overview of the legal bases 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 the country of registration. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.
● Consent (Article 6 (1) sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
● Contract performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR) - The 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 (Article 6 (1) sentence 1 lit. c) GDPR) – The processing is necessary to fulfill a legal obligation to which the controller is subject.
● Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.
National data protection regulations in Germany : In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases including profiling. In addition, state data protection laws of the individual federal states may apply.
Note on the validity of the GDPR and the Swiss DSG : This data protection notice serves to provide information in accordance with both the Swiss Federal Data Protection Act (Swiss DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "personal data requiring particular protection" used in the Swiss DSG, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the validity of the Swiss DSG.
4th OVERVIEW OF PROCESSING
The following overview summarises the types of data processed and the purposes of their processing and refers to the persons concerned.
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Types of data processed:
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● inventory data ● payment data ● contact details ● content data ● contract data ● usage data ● meta-, communication and procedural data ● event data (Facebook) |
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categories of data subjects |
● Customers ● interested parties ● communication partner ● users ● business and contractual partners |
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purposes of processing
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● provision of contractual services and fulfillment of contractual obligations [BG1] ● contact requests and communication ● security measures ● direct marketing ● reach measurement ● tracking ● office and organizational procedures ● remarketing ● conversion measurement ● click tracking ● target group formation ● A/B testing ● administration and response to inquiries ● feedback ● heatmaps ● marketing ● profiles with user-related information ● provision of our online offer and user-friendliness ● information technology infrastructure |
5th SAFETY MEASURES
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, securing availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to threats to data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): We use TLS encryption to protect the data you transmit via our online service. You can recognize encrypted connections of this type by the prefix https:// in the address bar of your browser.
6th TRANSMISSION OF PERSONAL DATA
As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer is for administrative purposes, the data is transferred based on our legitimate business and commercial interests or if it is necessary to fulfil our contractual obligations or if there is consent from the data subject or legal permission.
7th INTERNATIONAL DATA TRANSFERS
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transmission (Art. 49 Para. 1 GDPR). Furthermore, we will inform you of the basis for third-country transfers from the individual providers from the third country, with the adequacy decisions taking priority as the basis. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we inform you which service providers we use are certified under the Data Privacy Framework.
8th DELETION OF DATA
The data we process is deleted in accordance with legal requirements as soon as the consents to processing are revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
As part of our data protection information, we can provide users with further information on the deletion and storage of data that applies specifically to the respective processing operations.
9th RIGHTS OF THE DATA SUBJECTS
Rights of the data subjects under the GDPR: 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 to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
● Right to withdraw consent: You have the right to withdraw consent at any time.
● Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with legal requirements.
● Right to rectification: You have the right, in accordance with the statutory provisions, to request that the 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 statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
● Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
● Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you habitually 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.
10th USE OF COOKIES
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for different purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent : We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. Consent is not necessary in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve to display and operate the online offering, load balancing, security, storing user preferences and choices, or similar purposes related to providing the main and secondary functions of the online offering requested by users. Revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases : The data protection legal basis 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 with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.
Storage period : With regard to the storage period, the following types of cookies are distinguished:
● Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
● Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (so-called "opt-out") : Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. To do so, users can, among other things, restrict the use of cookies in the settings of their browser (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Cookie settings/opt-out option : We use the GDPR Legal Cookie App from iubenda srl on our website to inform you about the cookies and other technologies we use on our website, as well as to obtain, manage and document your consent, if required, to the processing of your personal data by these technologies. This is necessary in accordance with Art. 6 Paragraph 1 Clause 1 Letter c GDPR to fulfil our legal obligation pursuant to Art. 7 Paragraph 1 GDPR to be able to prove your consent to the processing of your personal data, to which we are subject. GDPR Legal Cookie is an offer from iubenda srl, Via San Raffaele, 1 - 20121 Milan, Italy, which processes your data on our behalf. After you have submitted your cookie declaration on our website, the GDPR Legal Cookie web server stores your anonymized IP address, the date and time of your declaration, browser information, the URL from which the declaration was sent, information about your consent behavior and an anonymous random key. In addition, a cookie is used that contains information about your consent behavior and the key. Your data will be deleted after twelve months unless you have expressly consented to further use of your data in accordance with Art. 6 Paragraph 1 Clause 1 Letter a of GDPR or we reserve the right to use the data in any other way that is permitted by law and about which we will inform you in this declaration.
Further information on processing procedures, methods and services :
● Processing of cookie data based on consent: We use a cookie consent management procedure within the framework of which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained and managed and revoked by the users. The declaration of consent is stored so that it does not have to be requested again and so that consent can be proven 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 about the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used; Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
● Cookie opt-out: In the footer of our website you will find a link via which you can change your cookie settings and revoke corresponding consent; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
11th BUSINESS SERVICES
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with the contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations. This includes in particular the obligations to provide the agreed services, any updating obligations and remedy in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and economical business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. 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 pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners are informed about other forms of processing, e.g. for marketing purposes, in the context of this data protection declaration.
We inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after statutory warranty and similar obligations have expired, i.e. generally after 4 years, unless the data is saved in a customer account, e.g. as long as it must be kept for legal archiving reasons. The statutory retention period is ten years for documents relevant for tax purposes as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, opening balance sheet, annual financial statements or management report was drawn up, the commercial or business letter was received or sent, or the accounting document was created, the recording was made or the other documents were created.
To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply to the relationship between the users and the providers.
● Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Affected persons: customers, interested parties, business and contractual partners.
● Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; security measures; contact requests and communication; office and organizational procedures. Administration and response to inquiries.
● Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR); Legal obligation (Art. 6 Para. 1 Clause 1 Letter c) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
Further information on processing procedures, methods and services:
● Customer account: Customers can create an account within our online offering (e.g. customer or user account, "customer account" for short). If the registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. As part of the registration and subsequent logins and use of the customer account, we save the customers' IP addresses along with the access times in order to be able to prove registration and prevent any misuse of the customer account. If the customer account has been terminated, the customer account data will be deleted after the termination date, unless it is kept for purposes other than making it available in the customer account or must be kept for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the customer's responsibility to back up their data when terminating the customer account; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
● Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and associated services, as well as to pay for and deliver or execute them. If necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the context of the order or comparable purchase process and includes the information required for delivery, provision and billing as well as contact information in order to be able to hold any consultations; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
12th PAYMENT METHODS
Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other service providers for this purpose (collectively "payment service providers").
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, amount and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information confirming or rejecting the payment. The payment service providers may transmit the data to credit agencies. [BG2] The purpose of this transmission is to check your identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
We do not carry out any Schufa checks ourselves. If you select advance payment as your payment method, no data will be transmitted to credit agencies.
The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and to assert revocation, information and other rights of those affected.
● Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Affected persons: customers, interested parties.
● Purposes of processing: Provision of contractual services and fulfillment of contractual obligations.
● Legal basis: Contractual performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR).
Further information on processing procedures, methods and services:
● PayPal : payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree);
Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg;
Legal basis: Contractual performance and pre-contractual inquiries (Article 6 (1) sentence 1 lit. b) GDPR);
Website: https://www.paypal.com/de .
Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .
● Credit card: If you pay on our website with your credit card, your credit card provider will receive information that you have placed an order with us. Your credit card provider may carry out a credit check. You can find more information on this on the respective website of your credit card provider.
● American Express
The provider of this payment service is American Express Europe SA, Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany (hereinafter “American Express”).
American Express may transfer data to its parent company in the USA. The data transfer to the USA is based on the Binding Corporate Rules. Details can be found here: https://www.americanexpress.com/en-pl/company/legal/privacy-centre/european-implementing-principles/ .
For further information, please see the American Express privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html .
● Mastercard
The provider of this payment service is Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium (hereinafter “Mastercard”).
Mastercard may transfer data to its parent company in the USA. Data transfer to the USA is based on Mastercard's Binding Corporate Rules. Details can be found here: https://www.mastercard.de/de-de/datenschutz.html and https://www.mastercard.us/content/dam/mccom/global/documents/mastercard-bcrs.pdf .
● VISA
The provider of this payment service is Visa Europe Services Inc., London branch, 1 Sheldon Square, London W2 6TT, United Kingdom (hereinafter “VISA”).
The UK is considered a safe third country in terms of data protection. This means that the UK has a level of data protection that corresponds to the level of data protection in the European Union.
VISA may transfer data to its parent company in the USA. The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zu-zustandigkeitsfragen-fur-den-ewr.html . For further information, please refer to VISA's privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html .
● payment on account
If you pay by invoice on our website, we ask you to transfer the amount on your invoice to our account within 14 days. Please be sure to include the invoice number.
● SEPA (transfer)/ prepayment:
If you pay on our website by SEPA direct debit or prepayment pay, our bank will receive your bank details to process the payment.
13th PROVISION OF THE ONLINE OFFER AND WEB HOSTING
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.
● Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); content data (e.g. entries in online forms); inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers). Contract data (e.g. subject of the contract, term, customer category).
● Data subjects: Users (e.g. website visitors, users of online services). Customers.
● Purposes of processing: Provision of our online offer and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures. Provision of contractual services and fulfillment of contractual obligations.
● Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
● Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called "web host") or obtain from other sources; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
● Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
● 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 other information regarding the e-mail sending (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data can also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the reception on our server; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
● Content delivery network: We use a "content delivery network" (CDN). A CDN is a service that helps deliver the content of an online offering, especially large media files such as graphics or program scripts, more quickly and securely using regionally distributed servers connected via the Internet; legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
● shopify: Platform through which e-commerce services are offered and carried out. The services and processes carried out in connection with them include in particular online shops, websites, their offers and content, community elements, purchase and payment transactions, customer communication as well as analysis and marketing;
Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland;
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR);
Website: https://www.shopify.de .
Privacy Policy: https://www.shopify.de/legal/datenschutz.
14th REGISTRATION, LOGIN AND USER ACCOUNT
Users can create a user account. During registration, users are provided with the required mandatory information and this information is processed for the purpose of providing the user account on the basis of contractual obligations. The data processed includes in particular the login information (user name, password and an email address).
When you use our registration and login functions and the user account, we save the IP address and the time of the respective user action. The data is saved on the basis of our legitimate interests and those of the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about processes relevant to their user account, such as technical changes.
● Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing: provision of contractual services and fulfillment of contractual obligations; security measures; administration and response to inquiries. Provision of our online offer and user-friendliness.
● Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR). Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
15th BLOGS AND PUBLICATION MEDIA
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent that it is 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 in the context of this data protection notice.
● Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Feedback (e.g. collecting feedback via online form); Provision of our online offer and user-friendliness; Security measures. Administration and answering of inquiries.
● Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services:
● Comments and contributions: When users leave comments or other contributions, their IP addresses can be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process the user's information 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 voting. The personal information provided in the comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
16th CONTACT AND REQUEST MANAGEMENT
When you contact us (e.g. by post, contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the inquiring persons is processed to the extent necessary to answer the contact inquiries and any requested measures.
● Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Data subjects: communication partners.
● Purposes of processing: contact requests and communication; administration and response to requests; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
● Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 Letter b) GDPR).
17th NEWSLETTERS AND ELECTRONIC NOTIFICATIONS
We only send newsletters, emails and other electronic notifications (hereinafter "newsletters") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure : Registration for our newsletter is always carried out using a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing : We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a block list (so-called "block list") for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping system.
Contents:
Information about us, our services, promotions and offers.
● Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status). 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 basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
● Opt-out option: You can cancel your subscription to our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably email.
Further information on processing procedures, methods and services:
● Measuring opening and click 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 shipping service provider, from its server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users. The measurement of the opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the user's consent. A separate revocation of the success measurement is unfortunately not possible; in this case the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; legal basis: consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).
18th ADVERTISING COMMUNICATION VIA E-MAIL, POST, FAX OR TELEPHONE
We process personal data for the purposes of advertising communication, which can take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke consent given at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently respecting the user's revocation or objection, we also store the data required to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).
● Types of data processed: Inventory data (e.g. names, addresses). Contact data (e.g. email, telephone numbers).
● Data subjects: communication partners.
● Purposes of processing: direct marketing (e.g. by e-mail or post).
● Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
19th WEB ANALYSIS, MONITORING AND OPTIMIZATION
Web analysis (also known as "reach measurement") is used to evaluate the flow of visitors to our online offering and can include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we can also use testing procedures to test and optimize, for example, different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in a 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 consented to us or the providers of the services we use collecting their location data, location data can also be processed.
The IP addresses of the users are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of web analysis, A/B testing and optimization, but rather pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
● Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; tracking (e.g. interest/behavior-related profiling, use of cookies); click tracking; A/B testing. Heatmaps (mouse movements by users that are summarized to form an overall picture).
● Security measures: IP masking (pseudonymization of the IP address).
● Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
Further information on processing procedures, methods and services: [BG3]
● Google Analytics 4 : We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR);
Website: https://marketingplatform.google.com/intl/de/about/analytics/ ;
Privacy Policy: https://policies.google.com/privacy ;
Data processing agreement: https://business.safety.google/adsprocessorterms/ ;
Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses ( https://business.safety.google/adsprocessorterms );
Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated .
Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
● Google Analytics in consent mode : In consent mode, Google processes users' personal data for measurement and advertising purposes, depending on the user's consent. Consent is obtained from users as part of our online services. If users' consent is completely lacking, the data is only processed at an aggregated level (i.e. not assigned to individual users and summarized). If the consent only covers statistical measurement, no users' personal data is processed for displaying ads or measuring advertising success (so-called "conversion");
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR).
Website: https://support.google.com/analytics/answer/9976101?hl=de.
● Google Tag Manager : Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not create user profiles or store cookies, for example. Google only learns the user's IP address, which is necessary to run the Google Tag Manager;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR);
Website: https://marketingplatform.google.com ;
Privacy Policy: https://policies.google.com/privacy ;
Data processing agreement: https://business.safety.google/adsprocessorterms .
Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms).
● Hotjar Observe : Software for analyzing and optimizing online offerings based on pseudonymous measurements and analyses of user behavior, which can include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offering (so-called heatmaps and recordings);
Service provider: Hotjar Ltd., 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta ;
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR);
Website: https://www.hotjar.com ;
Privacy Policy: https://www.hotjar.com/legal/policies/privacy ;
Deletion of data: The cookies that Hotjar uses have different "lifetimes"; some remain valid for up to 365 days, some only during the current visit;
Cookie policy: https://www.hotjar.com/legal/policies/cookie-information .
Opt-out option: https://www.hotjar.com/legal/compliance/opt-out.
● Google Analytics : We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, IP address data is used solely for this derivation of geolocation data before being immediately deleted. It is not logged, is not accessible, and is not used for any other purpose. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR);
Website: https://marketingplatform.google.com/intl/de/about/analytics/ ;
Privacy Policy: https://policies.google.com/privacy ;
Data processing agreement: https://business.safety.google/adsprocessorterms ;
Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses ( https://business.safety.google/adsprocessorterms );
Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated .
Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).
● Google invisible reCAPTCHA : We use the invisible reCAPTCHA service of Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland; "Google") on our website.
This serves the purpose of distinguishing between input by a human and automated, machine processing. In the background, Google collects and analyzes usage data that is used by Invisible reCaptcha to distinguish regular users from bots. For this purpose, your input is transmitted to Google and used there. In addition, the IP address and any other data required by Google for the Invisible reCAPTCHA service are transmitted to Google.
This data is processed by Google within the European Union and, where applicable, also in the USA. Google is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. The data transfer takes place on the basis of standard contractual clauses as appropriate guarantees for the protection of personal data, which can be viewed at: https://policies.google.com/privacy/frameworks.
Your personal data is processed on the basis of Art. 6 (1) (f) GDPR due to our overriding legitimate interest in protecting our website from automated spying, misuse and SPAM. You have the right to object to this processing of personal data concerning you based on Art. 6 (1) (f) GDPR at any time for reasons arising from your particular situation.
Further information about Google reCAPTCHA and the associated privacy policy can be found at: https://www.google.com/recaptcha/intro/android.html and https://www.google.com/privacy
20th ONLINE MARKETING
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used by means of which the information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used as well as information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process, but rather pseudonyms. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.
The information in the profiles is usually stored in cookies or using similar processes. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing processes we use and the network links the users' profiles with the aforementioned information. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, ie, for example, to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used will be stored for a period of two years.
● 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status); Event data (Facebook) ("Event data" is data that we can transmit to Facebook, for example via Facebook pixel (via apps or other means) and that relates to people or their actions. The data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences). Event data does not contain the actual content (such as comments written), login information, or contact information (i.e. no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it when our Facebook account is deleted).
● Data subjects: Users (e.g. website visitors, users of online services).
● Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavior-related profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness. Remarketing.
● Security measures: IP masking (pseudonymization of the IP address).
● Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR). Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR).
● Opt-out option: We refer to the data protection information of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.
Further information on processing procedures, methods and services:
● Meta pixels and target group formation (custom audiences) : With the help of the meta pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), the company Meta is able to determine the visitors to our online offer as a target group for the display of advertisements (so-called "meta ads"). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and do not appear annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a meta ad (so-called "conversion measurement");
Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland;
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR);
Website: https://www.facebook.com ;
Privacy Policy: https://www.facebook.com/about/privacy ;
Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing ;
Basis for transfer to third countries: EU-US Data Privacy Framework (DPF), standard contractual clauses ( https://www.facebook.com/legal/EU_data_transfer_addendum ).
Further information: Event data of users, i.e. behavioral and interest information, is processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint controllership ("Add for Controllers", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
● Facebook Ads : Placing advertisements within the Facebook platform and evaluating the ad results;
Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland;
Legal basis: Legitimate interests (Article 6 (1) sentence 1 lit. f) GDPR);
Website: https://www.facebook.com ;
Privacy Policy: https://www.facebook.com/about/privacy ;
Basis for third country transfer: EU-US Data Privacy Framework (DPF);
Opt-out option: We refer to the data protection and advertising settings in the user profile on the Facebook platform as well as in the context of Facebook's consent process and Facebook's contact options for exercising information and other data subject rights in Facebook's privacy policy.
Further information: Event data of users, i.e. behavioral and interest information, is processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint controllership ("Add for Controllers", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
● Google Ads and conversion measurement : online marketing procedures for the purpose of placing content and advertisements within the advertising network of the service provider (e.g. in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e. whether users have taken them as an opportunity to interact with the advertisements and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis:
Consent (Article 6 (1) sentence 1 lit. a) GDPR), Legitimate Interests (Article 6 (1) sentence 1 lit. f) GDPR);
Website: https://marketingplatform.google.com ;
Privacy Policy: https://policies.google.com/privacy ;
Basis for third country transfer: EU-US Data Privacy Framework (DPF);
Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
● Google Ads Remarketing : Google Remarketing, also called retargeting, is a technology that adds users who use an online service to a pseudonymous remarketing list so that users can be shown ads on other online offerings based on their visit to the online service;
Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland;
Legal basis: Consent (Article 6 (1) sentence 1 lit. a) GDPR);
Website: https://marketingplatform.google.com ;
Privacy Policy: https://policies.google.com/privacy ;
Basis for third country transfer: EU-US Data Privacy Framework (DPF);
Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
21st ONLINE MARKETING CHANGES AND UPDATE OF THE PRIVACY POLICY
We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting us.