Introduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data” for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as the “Online Offer”).
The terms used are not gender-specific.
As of 2 January 2023
Content overview
- introduction
- responsible person
- Overview of processing
- Relevant legal basis
- Security measures
- Transfer of personal data
- Deletion of data
- Use of cookies
- Business services
- Use of online platforms for bidding and sales purposes
- Payment procedure
- Provision of the online offer and web hosting
- Registration, login and user account
- Community features
- Blogs and publication media
- Contact and enquiry management
- Newsletter and electronic notifications
- Commercial communications via email, post, fax or telephone
- Surveys and polls
- Web analytics, monitoring and optimisation
- Online marketing
- Affiliate programmes and affiliate links
- Customer reviews and rating process
- Presence in social networks (social media)
- Plugins and embedded features and content
- Change and update privacy policy
- Rights of data subjects
- Definitions of terms
responsible
Werner Noske
Email address: werner@solidara.net
Phone: +49 1690 615 86 73
Imprint: https://solidara.net/imprint
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
- Inventory data.
- Payment data.
- Location data.
- Contact details.
- Content data.
- Contract data.
- Use data.
- Meta/communication data.
- Event data (Facebook).
Categories of people affected
- Customers.
- Interested parties.
- Communication partners.
- User.
- Business and contractual partners.
- Participant.
Purpose of processing
- Provision of contractual services and customer service.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- reach measurement.
- Tracking.
- Office and organisation procedures.
- Conversion measurement.
- Affiliate tracking.
- Manage and respond to queries.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Providing our online service and user experience.
- Information technology infrastructure.
Relevant legal bases
The following is an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be decisive in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6(1) p. 1 lit. a) DSGVO) – The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes.
- Contractual performance and pre-contractual enquiries (Art. 6(1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject’s request.
- Legal obligation (Art. 6(1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject
- Registered interests (Art. 6(1) p. 1 lit. f) DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or of 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.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, Land data protection laws of the individual Länder may apply.
Security measures
We shall implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with the law and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the various probabilities of occurrence and the level of risk 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 into, disclosure of, assurance of availability of, and segregation of, the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software as well as procedures according to the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.
Submission of personal data
Deletion of data
The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not necessary for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural person or legal entity.
Our privacy notices may also include further information on the retention and erasure of data that takes precedence for the processing operations in question.
Use of cookies
Storage duration: In terms of storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via the settings of their browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Cookie settings/ -opposition:
Link to cookie banner
Further guidance on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.
Business services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer enquiries.
We process this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. Furthermore, we process the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations as well as the company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. e-mail, telephone numbers); Contract data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- Affected persons: Customers; prospective customers; business and contractual partners.
- Purposes of processing: Providing contractual services and customer service; security measures; contact requests and communications; office and organisational procedures; managing and responding to enquiries.
- Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legal obligation (Art. 6 para. 1 p. 1 lit. c) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, “customer account” for short). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and to prevent any misuse of the customer account.If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the responsibility of the customers to secure their data when the customer account is terminated; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Agency services: We process our clients’ data in the context of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, acquire or commission the selected services or works as well as associated activities and to pay for and make available or execute or provide them.The required information is identified as such within the framework of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we obtain access to information of the end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Offer of software and platform services: We process the data of our users, registered and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to ensure the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Use of online platforms for supply and distribution purposes
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. e-mail, telephone numbers); Contractual data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- Affected persons: customers; users (e.g. website visitors, users of online services); business and contractual partners.
- Purposes of processing: Providing contractual services and customer service; marketing; providing our online offer and user experience.
- Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Kickstarter: Internet platform for project financing via crowdfunding as well as the sale of subscriptions and memberships, billing as well as the provision of access and payment procedures, for the implementation of which cookies are used and the IP address, date, time and other technical data about the Internet browser used, the operating system as well as inventory, contract and payment data of the users are processed; Service provider: Kickstarter, PBC, 58 Kent Street, Brooklyn, NY 11222 USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.kickstarter.com/; Privacy Policy: https://www.kickstarter.com/privacy.
- Startnext: Internet platform for project financing via crowdfunding as well as the sale of subscriptions and memberships, billing as well as the provision of access and payment procedures, for the implementation of which cookies are used and the IP address, date, time and other technical data about the Internet browser used, the operating system as well as inventory, contract and payment data of the users are processed; Service provider: Startnext GmbH, Grundstraße 1, 01326 Dresden, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.startnext.com/; Data protection statement: https://www.startnext.com/info/agb/datenschutz.html.
Payment procedure
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to data subjects and use other service providers in addition to banks and credit institutions for this purpose (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 the 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 with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of 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 general terms and conditions and the data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to payment transactions. We also refer to these for further information and the assertion of revocation, information and other data subject rights.
- Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: customers; prospective customers.
- Purposes of processing: Provision of contractual services and customer service.
- Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- PayPal: Payment services (technical connection of online payment methods) (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; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Website: https://www. paypal.com/en; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); security measures.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Collection of access data and log files: Access to our online offer is logged in the form of 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 may be used for security purposes, for example, to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilisation and stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes are exempt from deletion until the final clarification of the respective incident.
- ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://all-inkl.com/; Privacy Policy: https://all-inkl.com/datenschutzinformationen/; Processing Agreement: Provided by the service provider.
Registration, login and user account
Users can create a user account. As part of the registration process, users are provided with the required mandatory data and processed for the purposes of providing the user account on the basis of contractual obligation fulfilment. The processed data includes, in particular, the login information (user name, password as well as an e-mail address).
When using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.
Users may be informed by email about processes relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Providing contractual services and customer service; security measures; managing and responding to enquiries; providing our online service and user experience.
- Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Registration with clear name: Due to the nature of our community, we ask users to use our services only by using plain names. I.e. the use of pseudonyms is not permitted; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Deletion of data after termination: When users have terminated their user account, their data relating to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- No obligation to retain data: It is incumbent on users to back up their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Community functions
The community features we provide allow users to engage in conversations or other exchanges with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Providing contractual services and customer service; security measures.
- Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- Posts by users are public: The posts and content created by users are publicly visible and accessible; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
- Protection of own data: Users themselves decide what data they disclose about themselves within our online offer. For example, when users provide personal information or participate in conversations. We ask users to protect their data and to publish personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect access data very particularly and use secure passwords (i.e. especially character combinations that are as long and random as possible); Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication media”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Providing contractual services and customer service; feedback (e.g. collecting feedback via online form); providing our online service and user experience; security measures; contact requests and communication; managing and responding to requests.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- 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 security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.Furthermore, we reserve the right, based on our legitimate interests, to process the information of users for the purpose of spam detection.On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple voting. The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be permanently stored by us until the user objects; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Comment subscriptions: Follow-up comments can be subscribed to by users with their consent. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users may unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving users’ consent, we store the time of subscription along with users’ IP address and delete this information when users unsubscribe.You may unsubscribe from receiving our subscription at any time, i.e., revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent was previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Retrieval of WordPress emojis and smilies: Retrieval of WordPress emojis and smilies – Within our WordPress blog, graphical emojis (or smilies), i.e., small graphic files expressing emotions, are used for purposes of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
- Akismet Anti-Spam Check: Akismet Anti-Spam Check – We use the service “Akismet” based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment details are sent to a server in the USA, where they are analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used as well as the computer system and the time of the entry.Users are welcome to use pseudonyms or to refrain from entering their name or email address. They can completely prevent the transmission of data by not using our comment system. That would be a shame, but unfortunately we don’t see any alternatives that work as effectively; Service Provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
- Profile pictures from Gravatar: Profile pictures – We use the service Gravatar within our online offer and in particular in the blog.Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave posts or comments on other online presences (especially blogs) with the respective e-mail address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of the transmission of the email address. The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer post and comment authors the opportunity to personalise their posts with a profile picture. By displaying the images, Gravatar obtains the IP address of users, as this is necessary for a communication between a browser and an online service. If users do not want a user image linked to their Gravatar email address to appear in the comments, they should use an email address that is not on file with Gravatar to comment. We also point out that it is also possible to use an anonymous email address or no email address at all if users do not want their email address to be sent to Gravatar. Users can prevent the transmission of data completely by not using our commenting system; Service Provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.
Contact and enquiry management
When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed as far as this is necessary to answer the contact requests and any requested actions.
- Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: Communication partners.
- Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
- Contact form: When users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- HubSpot: Customer management and process and sales support with personalised customer care with multi-channel communication, i.e. management of customer enquiries from different channels and with analysis and feedback functions; Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.hubspot.de; Privacy Policy: https://legal. hubspot.com/en/privacy-policy; Contract for processing: https://legal.hubspot.com/dpa; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://legal.hubspot.com/dpa.
Newsletters and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletters”) only 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. Apart from that, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or other details if these are necessary for the purposes of the newsletter.
Double-Opt-In-Procedure: The registration for our newsletter is always carried out in a so-called Double-Opt-In-Procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process is carried out on the basis of our legitimate interests for the purposes of proving its proper course. Insofar as 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.
Contents:
Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. web pages visited, interest in content, access times).
- People concerned: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g. by email or post); provision of contractual services and customer service.
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Opposition (Opt-Out): You can cancel receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.
Further guidance on processing operations, procedures and services:
- Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened.
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Condition for the use of free services: Consent to the sending of mailings may be made conditional as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). Insofar as users wish to take advantage of the free service without subscribing to the newsletter, we request that you contact us.
- Click-Tip: Service Provider: CLICK-TIP Ltd., 15 Cambridge Court, 210 Shepherd’s Bush Road, London W6 7NJ, GB; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www. click-tip.com; Privacy Policy: https://www.klick-tipp.com/datenschutzerkl%C3%A4rung.
Commercial communication via e-mail, post, fax or telephone
We process personal data for the purposes of promotional communications, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
The recipients have the right to revoke consent given or to object to promotional communication at any time.
After revocation or objection, we store the data required to prove previous authorisation to contact or send for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, phone numbers).
- People concerned: Communication partners.
- Purposes of processing: Direct marketing (e.g. via e-mail or postal mail).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Surveys and polls
We conduct surveys and interviews to gather information for the purpose of the survey or interview as communicated. The surveys and questionnaires we conduct (hereinafter “surveys”) are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable the survey to be resumed with the aid of a cookie).
- Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: Communication partners; participants.
- Purpose of processing: Feedback (e.g. collecting feedback via online form).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Web analysis, monitoring and optimisation
Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analytics, we may also use testing procedures, for example, to test and optimise different versions of our online offering or its components.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (e.g. e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
- Security measures: IP masking (pseudonymisation of the IP address).
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or display of promotional and other content (collectively, “content”) based on users’ potential interests 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 information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, these may also be processed.
The details in the profiles are usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users’ profiles to the aforementioned data. We ask to note that users may make additional arrangements with the providers, e.g. by giving their consent as part of the registration process.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
- Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-based profiling, use of cookies); marketing; profiling with user-related information (creating user profiles); conversion measurement (measuring the effectiveness of marketing measures).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
- Opposition (Opt-Out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective regions:a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territory: https://optout.aboutads.info.
Further guidance on processing operations, procedures and services:
- Google Ads and conversion measurement: We use the online marketing procedure “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which users can be identified; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://marketingplatform.google.com; Privacy Policy: https://policies. google.com/privacy; Additional information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
Affiliate programmes and affiliate links
We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to third-party offers and services (collectively referred to as “affiliate links”) in our online offering. If users follow the Affiliate Links or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).
- Types of data processed: Contractual data (e.g. subject matter of contract, duration, customer category); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Affiliate tracking.
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Booking.com Affiliate Programme: Affiliate Marketing Affiliate Programme; Service Provider: Booking.com B.V., Herengracht 597, 1017 CE Amsterdam, The Netherlands; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www. booking.com; Privacy Policy: https://www.booking.com/content/privacy.de.html.
- Digistore24 affiliate programme: Affiliate marketing affiliate programme; Service provider: Digistore24 GmbH, St.-. Godehard-Straße 32, 31139 Hildesheim, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.digistore24.com; Privacy Policy: https://www.digistore24.com/page/privacy.
Customer reviews and rating procedures
We participate in review and rating processes to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the data protection notices of the providers also apply. As a rule, the rating also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
- Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: Customers; users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g. collecting feedback via online form); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Rating widget: We include so-called “rating widgets” in our online offer. A widget is a functional and content element integrated into our online offer that displays changeable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) which are necessary so that the content of the widget can be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- ProvenExpert: Rating platform; Service provider: Expert Systems AG, Quedlinburger Strasse 1, 10589 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.provenexpert.com/de-de/; Privacy Policy: https://www.provenexpert.com/de-de/datenschutzbestimmungen/.
- Trustpilot: Rating platform; Service provider: Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://de.trustpilot.com; Privacy Policy: https://de.legal.trustpilot.com/end-user-privacy-terms.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the possibilities to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further guidance on processing operations, procedures and services:
- Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www. facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a specific agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which specifically sets out the security measures that Facebook must observe and in which Facebook has agreed to comply with data subjects’ rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www. facebook.com/legal/EU_data_transfer_addendum; Further information: Shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. Joint accountability is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Data protection declaration: https://www.linkedin.com/legal/privacy-policy; Contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://legal. linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Data protection statement: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy statement: https://policies.google.com/privacy; Opt-out: https://adssettings.google.com/authenticated.
- Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded features and content
We embed functional and content elements in our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “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); inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); location data (information on the geographical position of a device or a person); event data (Facebook) (“event data” is data that is e.g. Event Data (Facebook) (“Event Data” is data that may be transmitted by us to Facebook, e.g. via the Facebook Pixel (via apps or other means), and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; the Event Data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
- People concerned: Users (e.g. website visitors, users of online services).
- Purposes of processing: Providing our online offer and user experience; providing contractual services and customer service; profiling user-related information (creating user profiles); marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further guidance on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimisation of their offer. – We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process this for the purpose of transmitting the software to the user’s browser and for security purposes, as well as for the evaluation and optimisation of their offer; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
- Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online service within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook. com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in connection with any transmission (but not the further processing) of “event data” that Facebook collects or receives in connection with any transmission through the Facebook social plugins (and content embedding features) that run on our website for the purposes of: a) displaying content and promotional information relevant to users’ perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook social plugins) to users of our website. (c) improving ad delivery and personalising features and content (e.g., improving the ability to identify which content or advertising information is likely to be of interest to users). We have entered into a specific agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum) which specifically sets out what security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not obtain details of individual users and are anonymous to us), this processing is not carried out under shared responsibility, but on the basis of a Data Processing Agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) the “Data Security Terms and Conditions” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the US on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
- Google Fonts (sourced from Google server): Sourced fonts (and symbols) for the purpose of technically secure, maintenance-free and efficient use of fonts and symbols in terms of timeliness and loading times, their uniform display and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the provider of the fonts in the USA – When visiting our online offer, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by each user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referral URL (i.e., the web page where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must match the font that is generated for the particular browser type. The user agent is logged primarily for debugging purposes and is used to generate aggregate usage statistics that measure the popularity of font families. These aggregate usage statistics are published on Google Fonts’ Analytics page. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregate report on top integrations based on the number of font requests. Google states that it does not use any of the information collected by Google Fonts to profile end users or serve targeted ads; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Grounds: Legitimate Interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Further Information: https://developers.google.com/fonts/faq/privacy?hl=de.
- Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. (f) DSGVO); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy.
- LinkedIn plugins and content: LinkedIn plugins and content- This may include, for example, content such as images, videos or text and buttons with which users can share content of this online offer within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy Policy: https://www. linkedin.com/legal/privacy-policy; Processing contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing level of data protection for processing in third countries): https://legal.linkedin.com/dpa; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- OpenStreetMap: We embed the maps of the service “OpenStreetMap”, which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). User data is used by OpenStreetMap exclusively for the purposes of displaying the map functions and for temporarily storing the selected settings. This data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the framework of the settings of their mobile devices); Service provider: OpenStreetMap Foundation (OSMF); Legal basis: Legitimate interests (Art. 6 para. 1 S.. 1 lit. f) DSGVO); Website: https://www.openstreetmap.de; Privacy Policy: https://wiki.osmfoundation.org/wiki/Privacy_Policy.
- Twitter plugins and content: Twitter plugins and buttons – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online service within Twitter; Service Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent Company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://twitter. com/en; Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
- YouTube videos: video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); website: https://www.youtube.com; Privacy Policy: https://policies. google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.
- Xing plugins and buttons: Xing plugins and buttons – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within Xing; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.xing.com; Data protection statement: https://privacy.xing.com/de/datenschutzerklaerung.
- Vimeo: video content; service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://vimeo. com; Privacy Policy: https://vimeo.com/privacy; Opt-Out: Please note that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (https://tools. google.com/dlpage/gaoptout?hl=en) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).
Change and update privacy policy
Where we provide addresses and contact information for companies and organisations in this Privacy Policy, please note that addresses may change over time and please check the information before contacting us.
Rights of data subjects
As data subjects, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right of objection: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw consent given at any time.
- Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
- Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased without delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
- Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another controller.
- Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.
Definitions of terms
This section provides an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
- Affiliate tracking: In the context of affiliate tracking, links with the help of which the linking websites refer users to websites with product or other offers are logged. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g. buy goods or use services). For this purpose, it is necessary for the providers to be able to track whether users who are interested in certain offers subsequently take advantage of them at the instigation of the affiliate links. It is therefore necessary for the functionality of affiliate links that they are supplemented by certain values that become part of the link or are stored elsewhere, e.g. in a cookie. The values include, in particular, the source website (referrer), the time, an online identifier of the operator 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, for example, advertising material ID, partner ID and categorisations
- Conversion measurement: Conversion measurement (also known as “visit action evaluation”) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
- Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or an association with an identifiable person (e.g. a person’s identity). (e.g. cookie) or to one or more particular characteristics which are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data which consists of using such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with web pages and their e.g. interaction with websites and their content, etc.), or to predict them (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behaviour or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
- Tracking: We speak of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: A “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
- Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
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