Introduction
With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: October 29, 2019
Table of contents
- Introduction
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Commercial and business services
- Payment service provider
- Communication via Messenger
- Provision of the online offer and web hosting
- Newsletter and broad communication
- Advertising communication by post, fax or telephone
- Online marketing
- Presences on Social Networks
- Plugins and embedded features as well as content
- Deletion of data
- Changes and updates to the privacy policy
- Rights of data subjects
- Definitions
Person responsible
Corsoela GmbH
Brüderstraße 6
04103 Leipzig
represented by the managing director Jacqueline Fischer
Contact:
Phone 0341 / 9 60 31 11
Fax 0341 / 9 60 31 46
E-Mail: kontakt@corsoela.de
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data (e.g. names, addresses).
- Content data (e.g. text entries, photographs, videos).
- Contact data (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Location data (data indicating the location of an end user’s device).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of affected persons
- Business and contractual partners.
- Interested parties.
- Communication partners.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of the processing
- Provision of our online offer and user-friendliness.
- Visitor action evaluation.
- Office and organizational procedures.
- Cross-device tracking (cross-device processing of user data for marketing purposes).
- Direct marketing (e.g. by email or post).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measuring the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Remarketing.
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- Security measures.
- Tracking (e.g. interest/behavioral profiling, use of cookies).
- Contractual services and service.
- Managing and responding to inquiries.
- Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases
In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply.
- Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR)– Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR)– Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. The data protection laws of the individual federal states may also apply.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well
Transfer and disclosure of personal data
As part 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. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.
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, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we only process or have the data processed in third countries with a recognized level of data protection, including 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 EU 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 information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”)
A distinction is made between the following cookie types and functions:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users that are used for reach measurement or marketing purposes can also 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: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
- Statistical, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user’s interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This process is also referred to as “tracking”, i.e. tracing the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). You can also object to the use of cookies for online marketing purposes by means of a variety of services, especially in the case of tracking, explained via the websites http://optout.aboutads.info and http://www.youronlinechoices.com/. In addition, you can receive further information on how to object in the context 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 users for their consent, which can be revoked at any time. Before consent has not been given, cookies that are necessary for the operation of our online offering are used at most. Their use is based on our interest and the interest of users in the expected functionality of our online offering.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.
We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of the contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we may take into account the profiles of registered users, including their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes as pseudonymously as possible and, where feasible, anonymously (e.g. as summarized data).
Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and associated services, as well as their payment and delivery or execution.
The required information is marked as such as part of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to consult with you if necessary.
- Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. e-mail, telephone numbers), Contract data (e.g. contract object, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Interested parties, business and contractual partners, customers.
- Purposes of Processing: Contractual services and support, contact requests and communication, Office and organizational procedures, Managing and responding to inquiries, Conversion tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles), Security measures.
- Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Payment service provider
In the context 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 use other payment service providers in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the payment service providers’ terms and conditions and data protection information.
Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.
- Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contract data (e.g. subject matter of the contract, duration, customer category), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Customers, interested parties.
- Purposes of processing: Contractual performance and service.
- Legal bases: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services used and service providers:
- PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Website: https://www.paypal.com/de; Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Communication via Messenger
We use messenger services for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.
You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is also processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to the messengers for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, internal contractual information requires special confidentiality or a reply via Messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.
- Processed data types: Contact data (e.g. e-mail, telephone numbers), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication, direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services used and service providers:
- Facebook-Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, Mutterunternehmen: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Possibility of objection (opt-out): https://www.facebook.com/settings?tab=ads.
Provision of the online offer and web hosting
In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the context of providing the hosting service may include all information relating to the users of our online service that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
- Processed data types: Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Newsletter and broad communication
We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) 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 user’s consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name so that we can address 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 in a so-called double opt-in procedure. This means that after registering, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with other people’s e-mail addresses. Subscriptions to 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 mailing service provider are also logged.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting 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 erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal bases: The newsletter is sent on the basis of the consent of the recipient or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Performance measurement: 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 mailing service provider, from their 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 for the technical improvement of 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 access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations help us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to.
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Meta/communication data (e.g. device information, IP addresses), Usage data (e.g. websites visited, interest in content, access times).
- Affected persons: Communication partner.
- Purposes of processing: direct marketing (e.g. by email or post), contact requests and communication.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
- Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Services used and service providers:
- Facebook-Messenger Broadcasts: Messenger with end-to-end encryption; service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Privacy Shield (Ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Widerspruchsmöglichkeit (Opt-Out): https://www.facebook.com/settings?tab=ads.
- Mailchimp: Email marketing platform; Service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/privacy/; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Advertising communication by post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels such as email, telephone, post or fax. In this context, we observe the legal requirements and obtain the necessary consent, unless the communication is permitted by law.
The recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time.
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Online marketing
We process personal data for online marketing purposes, 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 its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user data relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of 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 e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose 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 the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network links the user profiles to the aforementioned data. 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 procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Facebook pixel: With the help of the Facebook pixel, it is possible for Facebook to determine the visitors of our online offer as a target group for the display of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us 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/ ) 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), which we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).
- Processed Data Types: Usage data (e.g., visited websites, 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 device).
- Affected Persons: Users (e.g., website visitors, users of online services), interested parties.
- Purposes of Processing: Tracking (e.g., interest-based/behavioral profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creating user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g., access statistics, recognition of returning visitors), audience segmentation (determining target groups relevant for marketing purposes or other content distribution), 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 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
- Opt-Out Possibility: We refer you to the privacy notices of the respective providers and the opt-out options provided for those providers. If no explicit opt-out option is provided, you can disable cookies in your browser settings. However, this may limit the functionality of our online offerings. Therefore, we also recommend the following opt-out options, which are summarized and offered for specific areas:
a) Europe: https://www.youronlinechoices.eu.
b) Kanada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-Border:: http://optout.aboutads.info.
Services Used and Service Providers:
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags through a single interface (thus integrating Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal data of users. Regarding the processing of users’ personal data, please refer to the following information on Google services. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google Analytics: Online Marketing and Web Analytics; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out Option (Opt-Out): Opt-Out Plugin http://tools.google.com/dlpage/gaoptout?hl=de, Settings for Displaying Ad Impressions https://adssettings.google.com/authenticated.
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- Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads within the Google advertising network (e.g., in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by displaying ads in real-time based on users’ presumed interests. This allows us to display ads for and within our online offering in a more targeted manner, presenting users only with ads that potentially match their interests. For example, if a user is shown ads for products they have shown interest in on other online offerings, this is referred to as “remarketing.” Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google AdSense with Personalized Ads: We use the service Google AdSense with personalized ads, which helps display ads within our online offering, and we receive compensation for their display or other usage.; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Google AdSense with Non-Personalized Ads: We use the service Google AdSense with non-personalized ads, which helps display ads within our online offering, and we receive compensation for their display or other usage.; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Facebook-Pixel: Facebook-Pixel; Service Provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Right to Object (Opt-Out): https://www.facebook.com/settings?tab=ads.
Presences on Social Networks
We maintain online presences within social networks to communicate with users active there or to provide information about us.
We point out that user data may be processed outside the European Union. This may pose risks for users, as it could make the enforcement of user rights more difficult. Regarding US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we note that they are obligated to adhere to EU data protection standards.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles can then be used to display advertisements within and outside the networks that presumably match users’ interests. For these purposes, cookies are typically stored on users’ devices, which record their usage behavior and interests. Additionally, data may be stored in usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in).
For a detailed representation of the respective processing forms and the options to object (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of rights of the data subjects, we also point out that these can be most effectively asserted with the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. If you still need assistance, you can contact us.
- Processed Data Types: Inventory Data (e.g., names, addresses), Contact Data (e.g., email, phone numbers), Content Data (e.g., text entries, photographs, videos), Usage Data (e.g., visited websites, interest in content, access times), Meta/Communication Data (e.g., device information, IP addresses).
- Affected Persons: Users (e.g., website visitors, online service users).
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Implemented Services and Service Providers:
- Instagram : Social Network; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: http://instagram.com/about/legal/privacy.
- Facebook: Social Network; Service Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out Option (Objection Possibility): Ad Settings: https://www.facebook.com/settings?tab=ads;Additional Privacy Notice: Agreement on Joint Processing of Personal Data on Facebook Pages https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Notice for Facebook Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
Plugins and Embedded Features as well as Content
We integrate functional and content elements into our online services that are sourced from the servers of their respective providers (hereinafter referred to as “third parties”). This may include graphics, videos, social media buttons, and posts (hereinafter collectively referred to as “content”).
The integration always requires that the third-party providers of this content process the users’ IP addresses, as they would not be able to send the content to their browsers without the IP address. Therefore, the IP address is necessary for the display of this content or functions. We strive to use only those contents whose respective providers use the IP address solely for delivering the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. These pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users’ devices and can include technical information about the browser and operating system, referring websites, visit times, and other usage details of our online services, as well as being linked with such information from other sources.
Notes on Legal Bases: If we ask users for their consent to use third-party services, the legal basis for processing their data is consent. Otherwise, users’ data is processed based on our legitimate interests (i.e., the interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention to the information regarding the use of cookies in this privacy policy.
- Types of Data Processed: Usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
- Affected Persons: Users (e.g., website visitors, users of online services).
- Purposes of Processing: Provision of our online services and user-friendliness, contractual services and support.
- Legal Bases: Legitimate interests (Article 6(1)(f) of the GDPR).
Used Services and Service Providers:
- Google Maps: We integrate the maps from the “Google Maps” service provided by Google. The processed data may include, in particular, users’ IP addresses and location data, which are collected only with their consent (usually carried out through the settings of their mobile devices). Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://maps.google.de; Privacy policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Right to Object (Opt-Out): Opt-Out-Plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for Displaying Advertisements: https://adssettings.google.com/authenticated.
- ReCaptcha: We integrate the “reCAPTCHA” function to detect bots, for example, in online form entries. The behavioral data of users (e.g., mouse movements or queries) is analyzed to distinguish between humans and bots. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (Ensuring Data Protection Level for Data Processing in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Right to Object (Opt-Out): Opt-Out-Plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for Displaying Advertisements: https://adssettings.google.com/authenticated.
Deletion of Data
The data processed by us will be deleted in accordance with legal provisions as soon as the consents granted for processing are revoked or other permissions cease to exist (e.g., when the purpose of processing this data is no longer applicable or when they are no longer necessary for that 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 reasons or when their retention is necessary for the assertion, exercise, or defense of legal claims or to protect the rights of another natural or legal person.
Further information on the deletion of personal data may also be provided within the individual privacy notices of this privacy policy.
Changes and Updates to the Privacy Policy
We ask you to regularly review the contents of our privacy policy. We will update the privacy policy as soon as changes in our data processing require it. We will inform you when such changes necessitate an action on your part (e.g., consent) or any other individual notification.
Rights of Data Subjects
As data subjects, you have various rights under the GDPR, which are primarily derived from Articles 15 to 18 and 21 of the GDPR:
- Right to Object: You have the right to object at any time to the processing of your personal data based on Article 6(1)(e) or (f) of the GDPR for reasons related to your particular situation; this also applies to profiling based on these provisions. If your personal data is being processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such advertising purposes; this also applies to profiling insofar as it is related to such direct marketing.
- Right of Withdrawal for Consents: You have the right to withdraw your consents at any time.
- Right to Access: You have the right to request confirmation as to whether your personal data is being processed and to obtain information about that data, as well as further information and a copy of the data in accordance with legal provisions.
- Right to Rectification: You have the right, in accordance with legal provisions, to request the completion of your personal data or the correction of any inaccurate personal data concerning you.
- Right to Erasure and Restriction of Processing: You have the right, in accordance with legal provisions, to request the immediate deletion of your personal data or, alternatively, to request a restriction on the processing of that data in accordance with legal provisions.
- Right to Data Portability: You have the right to receive your personal data that you have provided to us, in accordance with legal provisions, in a structured, commonly used, and machine-readable format, or to request the transfer of that data to another controller.
- Complaint to Supervisory Authority: You also have the right, in accordance with legal provisions, to lodge a complaint with a supervisory authority, particularly in the member state of your habitual residence, your place of work, or the location of the alleged infringement, if you believe that the processing of your personal data infringes the GDPR.
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are primarily defined in Article 4 of the GDPR. The legal definitions are binding. The following explanations are intended mainly for clarity and understanding. The terms are listed in alphabetical order.
- Visitor Action Analysis: “Visitor Action Analysis” (in English, “Conversion Tracking”) refers to a method used to determine the effectiveness of marketing activities. Typically, a cookie is stored on users’ devices within the websites where the marketing activities take place, and it is then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
- Cross-Device Tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is collected across devices in so-called profiles by assigning an online identifier to the users. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices (e.g., mobile phones or desktop computers) used. In most cases, the online identifier is not linked to identifiable data, such as names, postal addresses, or email addresses.
- IP Masking: “IP Masking” is a method where 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 procedures, particularly in online marketing.
- Interest-Based and Behavioral Marketing: Interest-based and/or behavioral marketing refers to the practice of accurately predicting potential user interests in advertisements and other content. This is done based on information about their previous behavior (e.g., visiting specific websites and spending time on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. For these purposes, cookies are typically used.
- Conversion Measurement: Conversion measurement is a method used to determine the effectiveness of marketing activities. Generally, a cookie is stored on users’ devices within the websites where the marketing activities take place, and then it is retrieved again on the target website. For example, this allows us to determine whether the ads we placed on other websites were successful.
- Personal Data: “Personal data” refers to any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Profiling: “Profiling” refers to any kind of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person. Depending on the type of profiling, this may include information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behavior, and social interactions with others. Profiling is often used to predict interests in specific content or products, click behavior on a website, or location. For the purpose of profiling, cookies and web beacons are frequently used.
- Audience Measurement: Audience measurement (also known as web analytics) is used to analyze the visitor flows of an online service and can include the behavior or interests of visitors in certain information, such as website content. Through audience analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This enables them to better tailor the website’s content to the needs of their visitors. For the purpose of audience analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online service.
- Remarketing: “Remarketing” or “Retargeting” refers to the practice of noting which products a user has shown interest in on a website, in order to remind the user of these products on other websites, for example, through advertisements.
- Tracking: “Tracking” refers to the ability to trace the behavior of users across multiple online services. Typically, behavioral and interest information regarding the used online services is stored in cookies or on the servers of the providers of tracking technologies (known as profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
- Controller: A “Controller” is defined as the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: “Processing” refers to any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, including collection, analysis, storage, transmission, or deletion.
- Audience Targeting: Audience targeting, or “Custom Audiences,” refers to the practice of defining target groups for advertising purposes, such as displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be inferred that this user is interested in advertisements for similar products or the online store where they viewed the products. “Lookalike Audiences” refers to the practice of showing suitable content to users whose profiles or interests presumably match those of the users from whom the profiles were created. Cookies and web beacons are typically used for the purpose of creating Custom Audiences and Lookalike Audiences.