Privacy policy
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") 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 as part 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: 23 June 2020
Table of contents
- Introduction
- Responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission and disclosure of personal data
- Data processing in third countries
- use of cookies
- Commercial and business services
- Provision of the online offer and web hosting
- Blogs and publication media
- Contact
- Video conferencing, online meetings, webinars and screen sharing
- Newsletter and broad communication
- Promotional communication via e-mail, post, fax or telephone
- Online Marketing
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Deletion of data
- Modification and updating of the privacy policy
- Rights of data subjects
- Definitions
Responsible
Tobias Ossenberg-Engels
Widenmayerstr. 45
80538 Munich
Email address: t.ossenberg-engels@oecc.de
Imprint: www.urbanskyhubs.de
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 (e.g. names, addresses).
- Content data (e.g. text input, photographs, videos).
- Contact details (e.g. email, 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 terminal device).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of persons concerned
- Business and Contractual Partners.
- Interested parties.
- Communication partner.
- Users (e.g. website visitors, users of online services).
Purposes of the processing
- Provision of our online offer and user friendliness.
- Visit Action Evaluation.
- Office and organizational procedures.
- Cross-device tracking (processing of user data across devices for marketing purposes).
- Direct marketing (e.g. by e-mail or post).
- Feedback (e.g. collecting feedback via online form).
- Interest-based and behavioral marketing.
- Contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- Remarketing.
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- Security Measures.
- Tracking (e.g. interest/behavioural profiling, use of cookies).
- Contractual performance and service.
- Managing and responding to requests.
- Target group formation (determination of target groups relevant for marketing purposes or other output of content).
Relevant legal bases
In the following, we share 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 regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
- Consent (Art. 6(1)(1)(a) DSGVO) - The data subject has given his or her consent to the processing of personal data relating to him or her for a specific purpose or purposes.
- Contract 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 performance of pre-contractual measures taken at the data subject's request.
- Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Protection of vital interests (Art. 6(1) p. 1 lit. d. DSGVO) - Processing is necessary to protect the vital interests of the data subject or another natural person.
- Legitimate interests (Art. 6(1) p. 1 lit. f. DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
National data protection regulations in Germany: 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 as well as automated decision-making in individual cases including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, performance or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk 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.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, entry, disclosure, assurance of availability and separation 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 already take the protection of personal data into account in the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organisational units or persons or that it is 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 that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, 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 visited websites or domains and are stored by a browser on the user's computer. The primary purpose of a cookie is to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or 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").
The following cookie types and functions 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 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. Likewise, the interests of users used for reach measurement or marketing purposes can 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 may be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
- Statistics, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement 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 show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. . Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.
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 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 by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions 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 consent that can be revoked at any time. Before consent has been given, cookies will only be used if they are absolutely necessary for the operation of our online offer.
- 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).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the corporate organisation. We only disclose the data of the contractual partners to third parties within the framework of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the persons concerned (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 further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle 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 usually 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle 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.
- 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, term, customer category).
- Affected persons: Interested parties, business and contractual partners.
- Purposes of processing: contractual performance and service, contact requests and communication, office and organizational procedures, administration and response to requests.
- Legal basis: Contract fulfilment 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).
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the context of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each 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 case of abusive attacks, so-called DDoS attacks) and also to ensure the utilization of the servers and their stability.
- Types of data processed: Content data (e.g. text input, photographs, videos), usage data (e.g. web pages 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 p. 1 lit. f. DSGVO).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.
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, on the basis of our legitimate interests, to process the user's details 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 in order to avoid multiple votes.
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.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual performance and service, feedback (e.g. collecting feedback via online form), security measures, administration and response to enquiries.
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Protection of Vital Interests (Art. 6 para. 1 p. 1 lit. d. DSGVO).
Contact
When contacting us (e.g. via contact form, email, telephone or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.
The answering of contact requests in the context of contractual or pre-contractual relations is carried out for the fulfilment of our contractual obligations or for the answering of (pre)contractual requests and, moreover, on the basis of the legitimate interests in answering the requests.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
- Affected persons: Communication partners.
- Purposes of processing: contact requests and communication.
- Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Video conferencing, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as "Third Party Providers") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the Third-Party Providers and their services, we observe the legal requirements.
In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen contents.
If users are referred to third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Notes on legal bases: If we ask users for their consent to the use of third-party providers or certain functions (e.g. consent to a recording of calls), the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: contractual performance and service, contact requests and communication, office and organizational procedures.
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), 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).
Newsletter and broad communication
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. 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 for the purpose of a personal address in the newsletter, or further details if these are required 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 process. 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 e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. Processing of this data will be limited to the purpose of possible defence of claims. An individual request for deletion 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 for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. 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 basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it has been carried out in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Analysis and 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 shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval, are 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 behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather 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 its success are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system which serves both our business interests and the expectations of the users.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled, or it must be contradicted.
- 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. websites visited, interest in content, access times).
- Affected persons: Communication partners.
- Purposes of the processing: direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
- Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.
Promotional communication via e-mail, post, fax or telephone
We process personal data for the purposes of promotional communication, which may be via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communications 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 deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
- Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
- Affected persons: Communication partners.
- Purposes of the processing: direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Online Marketing
We process personal data for online marketing purposes, which may include, but are not limited to, marketing advertising space or displaying promotional and other content (collectively, "Content") based on users' potential interests and measuring 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 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 may also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of the online marketing procedure, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also 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 may be associated with the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network links the profiles of the users with the aforementioned data. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you 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 to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook Pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement").
- 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), location data (data indicating the location of an end user's device).
- Data subjects: Users (e.g. website visitors, users of online services), interested parties.
- Purposes of processing: tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
- Opt-out option: We refer to the data protection information of the respective providers and the opt-out options given for the providers. If no explicit opt-out option has been specified, you have the option of deactivating 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 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.
Services used and service providers:
- Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https: //policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https: //www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https: //adssettings.google.com/authenticated.
- Facebook Pixel: Service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https: //www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: https: //www.facebook.com/settings?tab=ads.
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, the enforcement of the rights of the users could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, the data of users within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior 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 computers of the users, in which the usage behavior 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 description of the respective forms of processing and the possibilities of objection (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: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used 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: https: //instagram.com/about/legal/privacy.
- Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy 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; Opt-out: Settings for advertisements: https: //www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy policy for Facebook pages: https: //www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https: //www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; opt-out: https: //www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: social network; service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy policy: https: //twitter.com/de/privacy, (settings) https://twitter.com/personalization; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to use only such content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.
Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's terminal device), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Provision of our online offer and user-friendliness, contractual performance and service, security measures, administration and response to enquiries.
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO).
Services used and service providers:
- 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 the users, which, however, are not collected without their consent (usually executed as part of the settings of their mobile devices); 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://cloud.google.com/maps-platform; data protection declaration: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https: //www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; opt-out option: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https: //adssettings.google.com/authenticated.
- YouTube videos: Video content; 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.youtube.com; Privacy policy: https: //policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https: //www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https: //adssettings.google.com/authenticated.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required 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. This means that 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 or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.
Modification and updating of the privacy policy
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right to object: 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 is 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 of revocation for consents: You have the right to revoke any consent you have given at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data in question is being processed and to be informed of such data and to obtain further information and a copy of the data in accordance with the law.
- Right to rectification: In accordance with the law, you have the right 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 immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
- Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
- Complaint to supervisory authority: You also have the right, in accordance with the law, 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 GDPR.
Definitions
This section provides you with an overview of the terms used in this privacy policy. 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 aid understanding. The terms are sorted alphabetically.
- Conversion tracking: "Conversion tracking" refers to a procedure that can be used to determine the effectiveness of marketing measures. 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).
- Cross-device tracking: Cross-device tracking is a form of tracking in which users' behavioural and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analysed for marketing purposes, irrespective of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
- IP masking: "IP masking" refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
- Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when the potential interests of users in advertisements and other content are determined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. 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. 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" is any form of automated processing of personal data that involves the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (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.
- Reachmeasurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors' behavior or interests in certain information, such as website 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 recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: We speak of "remarketing" or "retargeting" when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: We speak of "tracking" when the behaviour of users can be traced across several online services. As a rule, behavioural and interest information with regard to the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: 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.
- Target group formation: We speak of target group formation (or "Custom Audiences") when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which he viewed the products. In turn, we speak of "lookalike audiences" (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.