Introduction

With the following data protection declaration we would like to inform you about what types of your personal data (hereinafter also referred to briefly as “data”) we process for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications as well as within external online presences, such as our social media profiles (collectively referred to as “Online Offer”).

The terms used are not gender specific.

As of June 30, 2020

Index

Responsible

Mirko peters / How to go digital
Women’s Gate Wall 68
90402 Nuremberg

E-mail address: mirko.peters@so-geht.digital

Overview of processing operations

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

Types of data processed

  • inventory data (e.g. names, addresses).
  • content data (e.g. text input, photographs, videos).
  • Contact details (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).
  • Social data (data subject to social secrecy (Section 35 SGB I) and processed, for example, by social security institutions, social welfare institutions or pension authorities).
  • Location data (data that indicates the location of an end-user’s terminal).

Categories of affected persons

  • employees (e.g. employees, applicants, former employees).
  • Interested parties.
  • Communication.
  • Customers.
  • users (e.g. website visitors, users of online services).

Purposes of processing

  • Affiliate tracking.
  • Registration.
  • Provision of our online offer and user-friendliness.
  • Visiting action evaluation.
  • office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or postal).
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling.
  • Remarketing.
  • Range measurement (e.g. access statistics, detection of returning visitors).
  • Security.
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual services and services.
  • Manage and respond to requests.
  • Target group ingesity (determination of target groups relevant for marketing purposes or other content output).

Relevant legal bases

In the following, we provide the legal bases of the General Data Protection Regulation (GDPR), on the basis of which we process the personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements may apply in your or our country of residence and residence. Should more specific legal bases be relevant in individual cases, we will inform you of them in the data protection declaration.

  • Consent (Art. 6 sec. 1 p. 1 lit. a GDPR) – The data subject has given his consent to the processing of the personal data concerning him or her for a specific purpose or several specific purposes.
  • Performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 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, which take place at the request of the data subject.
  • Protection of vital interests (Art. 6 sec. 1 p. 1 lit. d. GDPR) – Processing is necessary to protect the vital interests of the data subject or another natural person.
  • Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, prevail.

Security

We shall take appropriate technical and organisational measures to ensure a level of protection commensurate with the risk, taking into account the state of the art, the cost of implementation and the nature, the scope of the processing, as well as the different probability of occurrence and the extent of the threat to the rights and freedoms of natural persons.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry, disclosure, securing availability and separation. In addition, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data and reactions to the risk of the data. Furthermore, we take into account the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technical design and through data protection-friendly presets.

Transfer and disclosure of personal data

In the context of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers entrusted with IT tasks or providers of services and content that are integrated into a website. In such a case, we comply with the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data, which serve the protection of your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this is only in accordance with the legal requirements.

Subject to express consent or contractual or legal transmission, we will process or have the data processed only in third countries with a recognised level of data protection, which includes the US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (art. 44 to 49 GDPR, information page of the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

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

The following types of cookies and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Similarly, the interests of users used for range measurement or marketing purposes may be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies may be strictly necessary for the operation of a website (e.g. to store logins or other user entries or for reasons of security).
  • Statistics, marketing and personalization cookies: In addition, cookies are usually also used in the context of range measurement and when the interests of a user or his behaviour (e.g. viewing certain content, benefits of functions, etc.) are stored on individual websites in a user profile. Such profiles are used to display to users, for example, content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. . Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using 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 the processing of your data is the declared consent. Otherwise, the data processed by cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary, in order to fulfil our contractual obligations.

Storage time: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General notes on revocation and opposition (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively, “opt-out”). You can first declare your objection by means of the settings of your browser, e.g. by disabling the use of cookies (whereby the functionality of our online offer may also be limited). An objection to the use of cookies for online marketing purposes can also be explained by means of a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection within the scope of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask the users for a revocable consent at any time. Until consent has been given, cookies are used, which are absolutely necessary for the operation of our online offer.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance.

The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that is incurred in the context of use and communication. This regularly includes the IP address necessary to deliver the contents of online offers to browsers and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data for every access to the server (so-called server log files). The server log files may include the address and name of the retrieved websites and files, the date and time of the retrieval, the amount of data transferred, the notification of successful retrieval, the 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, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: 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).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Registration, registration and user account

Users can create a user account. As part of the registration process, the users are provided with the required information and processed for the purpose of providing the user account on the basis of contractual obligations. The data processed 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 can be informed by e-mail about processes that are 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 legal retention obligation. It is the responsibility of the users to secure their data before the end of the contract if they are terminated. We are entitled to permanently delete all data of the user stored during the term of the contract.

As part of the use of our registration and registration functions as well as the use of 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 that of the users in a protection against misuse and other unauthorized use. In principle, 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.

Online Forum: Participation in the Forum requires registration, subject to other information in the registration form, a password or your name, a password and the e-mail address to which the access data is sent. For security reasons, the password should be state-of-the-art, i.e. complicated (this is what users will be advised to do in the registration process if necessary) and should not be used elsewhere. The posts in the Forum are visible to the public, unless their visibility is limited to specific members or groups of members. The authors’ contributions are stored with their names, if registered or specified, the time and the entry content. In the case of registrations and when writing entries, the IP addresses of the users are also stored if the entries have an inadmissible content and the IP addresses could be used for legal action. The controller reserves the right to delete the registrations and entries on the basis of a proper consideration.

Two-factor authentication:Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password.

For this purpose, you must perform a further authentication action in addition to your password (e.g. enter a code sent to a mobile device). We will inform you about the procedure we have used.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and services, security measures, management and response of enquiries.
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Single sign-on login

“Single sign-on” or “single sign-on” or “authentication” means methods that allow users to log in to a provider of single sign-on procedures (e.g. a social network) with the help of a user account. The prerequisite for single sign-on authentication is that the users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via button.

Authentication is done directly with the respective single sign-on provider. In the context of such authentication, we receive a user ID with the information that the user is logged in to the respective single sign-on provider under this user ID and an ID that is no longer usable for us for other purposes (so-called “User Handle”). Whether additional data is transmitted to us depends solely on the single sign-on method used, on the data releases selected in the context of authentication and also on which data users have released to the single sign-on provider in the privacy or other settings of the user account. Depending on the single sign-on provider and the choice of users, different data can be, usually the email address and the user name. The password entered by the single sign-on provider as part of the single sign-on procedure is not visible to us, nor is it stored by us.

Users are asked to note that their data stored by us can be automatically compared with their user account with the single sign-on provider, but this is not always possible or actually done. For example, if the e-mail addresses of the users change, they must change them manually in their user account with us.

If agreed with the users, we may process the single sign-on application within the scope of or before the fulfilment of the contract, insofar as the users have been requested, within the framework of a consent and otherwise use it on the basis of the legitimate interests of our side and the interests of the users in an effective and secure registration system.

Should users decide to stop linking their user account with the single sign-on provider for the single sign-on procedure, they must disconnect from the single sign-on provider within their user account. If users wish to delete their data with us, they must cancel their registration with us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and services, registration procedure.
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Services and service providers used:

Blogs and publication media

We use blogs or similar means of online communication and publication (hereinafter “publication medium”). The data of the readers are processed for the purposes of the publication medium only to the extent that it is necessary for its presentation and communication between authors and readers or for reasons of security. In addition, we refer to the information on the processing of visitors to our publication medium within the framework of these data protection notices.

Comments and Posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our safety if someone leaves illegal content in comments and posts (insults, forbidden political propaganda, etc.). In this case, we ourselves can be prosecuted for commentor or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right to process the information of the users for 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 their duration in the case of surveys and to use cookies in order to avoid multiple votes.

The information provided in the context of the comments and contributions about the person, any contact and website information as well as the content information will be stored permanently by us until the user objects.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and services, feedback (e.g. collecting feedback via online form), security measures, management and answering of enquiries.
  • Legal bases: Performance of contracts and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR), consent (Art. 6 sec. 1 p. 1 lit. a GDPR), protection of vital interests (Art. 6 sec. 1 p. 1 lit. d. GDPR).

Contact

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

The answer to contact requests in the context of contractual or pre-contractual relationships is to fulfil our contractual obligations or to answer (pre)contractual enquiries and, in addition, on the basis of the legitimate interests in answering the enquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Persons affected: Communication.
  • Purposes of processing: Contact requests and communication.
  • Legal bases: Performance of contracts and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Videoconferencing, online meetings, webinars and screen sharing

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

Within this framework, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, login and contact details, visual and vocal posts, as well as input into chats and shared screen content.

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

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: Contractual services and services, contact requests and communication, office and organizational procedures.
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Services and service providers used:

Music and podcasts

We use hosting and analysis services from service providers to provide our audio content for listening to or downloading and to obtain statistical information on how to retrieve the audio content.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics, detection of returning visitors), visit action evaluation, profiling (creating user profiles).

Services and service providers used:

Cloud services

We use software services accessible over the Internet and performed on their providers’ servers (so-called “cloud services,” also known as “Software as a Service”) for the following purposes: document storage and management, calendar management, email delivery, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information, as well as chats and participation in audio and video conferencing.

In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this data protection declaration. This data may include, in particular, master data and contact data of the users, data on transactions, contracts, other processes and their contents. Cloud service providers also process usage data and metadata they use for security and service optimization purposes.

Insofar as we provide documents and content to other users or publicly accessible websites, providers may store cookies on users’ devices for the purpose of web analysis or to remember user settings (e.g. in the case of media control).

Notes on legal bases: If we ask for consent in the use of cloud services, the legal basis of the processing is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, the data of the users will be processed on the basis of our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: Customers, employees (e.g. employees, applicants, former employees), prospects, communication partners.
  • Purposes of processing: office and organizational procedures.
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Services and service providers used:

Newsletter and broad communication

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

In order to subscribe to our newsletters, it is always sufficient if you provide your e-mail address. However, we may ask you to provide a name for personal address in the newsletter, or other information if required for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is basically done in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign 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 storing the login and confirmation time as well as the IP address. The changes to your data stored by the shipping service provider will also be logged.

Deletion and restriction of processing: We may store the e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense of claims. An individual request for cancellation 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 in a block list (so-called “blacklist”) for this purpose alone.

The registration procedure is logged on the basis of our legitimate interests for the purpose of proving its proper conduct. Insofar as we commission a service provider to send e-mails, this is based on our legitimate interests in an efficient and secure shipping system.

Notes on legal bases: The newsletters are sent on the basis of the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as 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.

Contents: Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses), contact details (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).
  • Persons affected: Communication.
  • Purposes of processing: Direct marketing (e.g. by e-mail or postal).
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
  • Possibility of opposition (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consents or object to further receipt. You can either find a link to cancel the newsletter at the end of each newsletter or otherwise use one of the above-mentioned contact options, preferably e-mail.

Services and service providers used:

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 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 methods are used by which the information relevant to the presentation of the aforementioned contents about the user is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, these can also be processed.

The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. As a general rule, the online marketing process does not store clear 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 cookies or by similar procedures. These cookies can later generally also be used on other websites that use the same online marketing method, read out 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.

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

In principle, we only have access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

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

Target grouping with Google Analytics: We use Google Analytics to display the ads displayed within google and its partners, only those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products determined by the websites visited) that we transmit to Google (so-called “Remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads meet the potential interest of users

Facebook pixels: With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as the target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to use the Facebook ads we serve only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) which have also shown an interest in our online offer or which have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads meet the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook ads for statistical and market research purposes by seeing if users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end-user’s terminal), social data (data that are subject to social secrecy (Section 35 SGB I) and are processed e.g. by social security institutions, social welfare institutions or pension authorities.
  • Persons affected: Users (e.g. website visitors, users of online services), interested parties, customers, employees (e.g. employees, applicants, former employees), communication partners.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural Marketing, profiling (creating user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, detection of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).
  • Possibility of opposition (opt-out): We refer to the data protection notices of the respective providers and the possible objections to the providers (so-called “opt-out”). Unless an explicit opt-out option has been specified, you may switch off cookies in your browser settings. However, this may limit the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary to specific areas: a) Europe: https://www.youronlinechoices.eu. (b) Canada: https://www.youradchoices.ca/choices. (c) USA: https://www.aboutads.info/choices. (d) Across the territorial basis: https://optout.aboutads.info.

Services and service providers used:

Social media presences

We maintain online presences within social networks and process users’ data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that users’ data can be processed outside the European Union. This can create risks for users, as this could, for example, make it more difficult to enforce users’ rights. With regard to U.S. providers that are certified under the Privacy Shield or offer similar guarantees of a secure level of privacy, we would like to point out that they are committed to complying with EU data protection standards.

Furthermore, users’ data within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created based on the user behaviour and the resulting interests of the users. The user profiles can in turn be used to display advertisements inside and outside the networks, for example, which presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the user’s usage behaviour and the interests of the users are stored. Furthermore, data may 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 processing methods and the opt-out, we refer to the data protection declarations and information of the operators of the respective networks.

We would also like to point out that these can be asserted most effectively by the providers in the case of requests for information and the assertion of data subjects’ rights. Only the providers have access to the data of the users and can take direct action and provide information. If you still need help, you can contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, detection of returning visitors), affiliate tracking.
  • Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Services and service providers used:

Plugins and embedded functions as well as content

We incorporate functional and content elements from the servers of their respective providers (hereinafter referred to as “Third Parties”) in our online offering. These may include graphics, videos, social media buttons, and posts (hereinafter referred to as “Content”).

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

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service.
  • Legal bases: Eligible interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Services and service providers used:

  • Google Fonts: We include the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically safe, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration. Service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

Planning, organization and tools

We use third-party services, platforms and software (hereinafter referred to as “Third Party”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.

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

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

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons affected: communication partners, users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 sec. 1 p. 1 lit. a GDPR), performance of the contract and pre-contractual enquiries (Art. 6 sec. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 sec. 1 p. 1 lit. f. GDPR).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permission is omitted (e.g. if the purpose of the processing of this data has ceased or they are not necessary for the purpose).

Unless the data is deleted because it is necessary for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be made within the framework of the individual data protection notices of this data protection declaration.

Modification and updating of the Privacy Policy

We kindly ask you to keep up to know regularly about the content of our privacy policy. We will adjust the Privacy Policy as soon as the changes to the data processing we perform make this necessary. We will inform you as soon as the changes require an act of participation on your part (e.g. consent) or any 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 them.

Rights of data subjects

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

  • Right to object: For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you, which is subject to Article 6(4) of the Year. 1 lit. e or f GDPR to object; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling in so far as it is related to such direct marketing.
  • Right of withdrawal in case of consent: You have the right to revoke consents given at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copy of the data in accordance with the legal requirements.
  • Right to correction: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that you delete data concerning you immediately or, alternatively, to request a restriction on the processing of the data in accordance with the statutory requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request their transmission to another controller.
  • Complaint to supervisory authority: You also have the right, in accordance with the legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, workplace or place of alleged infringement, if you believe that the processing of personal data concerning you is in breach of the GDPR.

Definitions

This section provides an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and are defined above all in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended for understanding. The terms are sorted alphabetically.

  • Affiliate tracking: As part of the affiliate tracking, links with which the linking websites refer users to websites with product or other offers are logged. The operators of the respective linked websites can receive a commission if users follow these so-called affiliate links and then take advantage of the offers (e.g. goods or use services). For this purpose, it is necessary that the providers can track whether users who are interested in certain offers subsequently perceive them at the instigation of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary that they are supplemented by certain values that become part of the link or are otherwise stored, e.g. in a cookie. The values include in particular the initial website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user as well as tracking-specific values, such as advertising media ID, partner ID and categorizations.
  • Visit action evaluation: “Conversion Tracking” means a method of determining the effectiveness of marketing activities. As a rule, a cookie is stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the destination website. For example, we can track whether the ads we run on other websites were successful).
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which user behaviour al-interest information is collected across devices in so-called profiles by assocising an online identifier to users. This allows user information to be analyzed for marketing purposes, regardless of browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online ID is not associated with clear data, such as names, postal addresses, or e-mail addresses.
  • IP Masking: IP masking is a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioural marketing: Interest- and/or behavioral marketing is referred to when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which are stored in a so-called profile. Cookies are usually 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 users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the destination website. For example, we can track whether the ads we run on other websites were successful.
  • Personal data: “Personal Data” means any information relating to an identified or identifiable natural person (‘the data subject’); Identifiable is a natural person who can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or 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 type of automated processing of personal data that consists in the use of such personal data to analyse certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, purchasing behaviour, social interactions with other people). , or to predict them (e.g. interests in specific content or products, click-through behavior on a website or where you are). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: The range measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offer and may include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of the range analysis, website owners can, for example, recognize the time at which visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the contents of the website to the needs of their visitors. For the purposes of range analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offer.
  • Remarketing: “Remarketing” or “retargeting” is referred to when, for example, for advertising purposes, it is noted 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 called when the behaviour of users can be tracked across multiple 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 person’ means the natural or legal person, authority, body or other body which decides, alone or jointly with others, on the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or series of operations carried out with or without the help of automated procedures in connection with personal data. The term goes far and covers virtually every use of data, be it the collection, the evaluating, the saving, the transmission or the deletion.
  • Target group formation: Target groups (or “Custom Audiences”) are defined when target groups are designated for advertising purposes, e.g. displayof advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that that user is interested in advertisements for similar products or the online shop in which he viewed the products. “Lookalike Audiences” (or similar audiences) are referred to when the content deemed appropriate is displayed to users whose profiles or interests are presumed to correspond to the users to whom the profiles were created. Cookies and web beacons are usually used for the purposes of creating Custom Audiences and Lookalike Audiences.

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