Privacy policy
Privacy Policy
Non-binding English translation for your convenience. The German version is the legally binding one.
Preamble
With the following privacy policy, we would like to inform you about which types of your personal data (hereinafter also referred to as "data" for short) we process, for which purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing 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 offering").
The terms used are not gender-specific.
Last updated: 19 March 2024
Table of contents
- Preamble
- Controller
- Overview of processing operations
- Relevant legal bases
- Security measures
- Transfer of personal data
- International data transfers
- Erasure of data
- Rights of data subjects
- Business services
- Use of online platforms for offering and sales purposes
- Providers and services used in the course of business activities
- Payment methods
- Provision of the online offering and web hosting
- Use of cookies
- Contact and enquiry management
- Cloud services
- Newsletters and electronic notifications
- Prize draws and competitions
- Surveys and polls
- Web analytics, monitoring and optimisation
- Online marketing
- Presences on social networks (social media)
- Plugins and embedded functions and content
- Management, organisation and support tools
- Changes and updates to the privacy policy
- Definitions of terms
Controller
el origen food GmbH
Große Reichenstraße 27
20457 Hamburg
Deutschland
E-mail address:
Legal notice:
https://www.elorigenfood.de/policies/legal-notice
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of data processed
- Inventory data.
- Payment data.
- Location data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Contact information (Facebook).
- Event data (Facebook).
Categories of data subjects
- Customers.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Participants in prize draws and competitions.
- Business and contractual partners.
- Participants.
Purposes of processing
- Provision of contractual services and fulfilment of contractual obligations.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organisational procedures.
- Remarketing.
- Conversion measurement.
- Click tracking.
- Target group formation.
- A/B tests.
- Management and answering of enquiries.
- Conducting prize draws and competitions.
- Feedback.
- Heatmaps.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or registered office. Should more specific legal bases also be relevant in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of his or her personal data for one specific purpose or several particular purposes.
- Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take pre-contractual steps at the request of the data subject.
- Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6(1)(f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection provisions in Germany: In addition to the data protection provisions of the GDPR, national data protection provisions apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG (German Federal Data Protection Act)). The BDSG contains, in particular, special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual German federal states (Landesdatenschutzgesetze) may apply.
Note on the applicability of the GDPR and the Swiss FADP: This privacy notice serves to provide information both under the Swiss Federal Act on Data Protection (Swiss FADP) and under the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used owing to their broader territorial application and comprehensibility. In particular, instead of the terms "Bearbeitung" (processing) of "Personendaten" (personal data), "überwiegendes Interesse" (overriding interest) and "besonders schützenswerte Personendaten" (sensitive personal data) used in the Swiss FADP, the terms "processing" of "personal data" as well as "legitimate interest" and "special categories of data" used in the GDPR are used. However, within the scope of application of the Swiss FADP, the legal meaning of the terms continues to be determined in accordance with the Swiss FADP.
Security measures
In accordance with the statutory requirements, and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, safeguarding the availability of and separation of the data. In addition, we have established procedures that ensure the exercise of data subjects' rights, the erasure of data and responses to threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.
TLS/SSL encryption (https): In order to protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
Transfer of personal data
In the course of our processing of personal data, it may happen that the data are transferred to, or disclosed to, other bodies, companies, legally independent organisational units or persons. The recipients of these data may include, for example, service providers entrusted with IT tasks or providers of services and content that are embedded in a website. In such cases, we observe the statutory requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
Data processing in third countries: Where we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is done only in accordance with the statutory requirements. Where the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers take place only if the level of data protection is otherwise ensured, in particular by standard contractual clauses (Art. 46(2)(c) GDPR), explicit consent or in the case of a transfer that is contractually or legally required (Art. 49(1) GDPR). In addition, we inform you of the bases for third-country transfers for the individual providers from the third country, with adequacy decisions taking precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
EU-US Trans-Atlantic Data Privacy Framework: Within the scope of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We inform you in this privacy notice which of the service providers we use are certified under the Data Privacy Framework.
Erasure of data
The data processed by us are erased in accordance with the statutory requirements as soon as the consents permitting their processing are withdrawn or other permissions cease to apply (e.g. if the purpose of processing these data has ceased to apply or they are not necessary for the purpose). Where the data are not erased because they are required for other, legally permissible purposes, their processing is restricted to those purposes. This means that the data are 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 establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person. Within the scope of our privacy notice, we may provide users with further information on the erasure and retention of data that applies specifically to the respective processing operations.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
- Right of access: You have the right to request confirmation as to whether the data in question are being processed, and to access to these data as well as to further information and a copy of the data in accordance with the statutory requirements.
- Right to rectification: In accordance with the statutory requirements, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, to request restriction of the processing of the data in accordance with the statutory requirements.
- Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the statutory requirements, or to request their transmission to another controller.
- Complaint to a supervisory authority: In accordance with the statutory requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State of your habitual residence, the supervisory authority of your place of work or of the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Business Services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), within the scope of contractual and comparable legal relationships as well as related measures, and within the scope of communication with the contractual partners (or at the pre-contractual stage), e.g. in order to respond to enquiries.
We process this data in order to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any obligations to provide updates, and remedies in the event of warranty claims and other service disruptions. In addition, we process the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations as well as for the organisation of our company. Furthermore, we process the data on the basis of our legitimate interests in proper and economically efficient business management and in security measures to protect our contractual partners and our business operations from misuse and from threats to 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 advisers, payment service providers or tax authorities). Within the scope 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 for the fulfilment of legal obligations. Contractual partners are informed about further forms of processing, e.g. for marketing purposes, within this privacy policy.
We inform the contractual partners which data is required for the aforementioned 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 statutory warranty and comparable obligations, i.e. in principle after 4 years, unless the data is stored in a customer account, e.g. for as long as it must be retained for statutory archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions and other organisational documents required to understand these documents, and accounting vouchers, and six years for commercial and business letters received and reproductions of commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting voucher was created, or in which the record was made or the other documents were created.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers; prospective customers. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; contact enquiries and communication; office and organisational procedures. Managing and responding to enquiries.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Customer account: Customers can create an account within our online offering (e.g. customer or user account, "customer account" for short). If registration of a customer account is required, customers will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the times of access in order to be able to prove the registration and to prevent any misuse of the customer account. If the customer account has been terminated, the data of the customer account will be deleted after the date of termination, unless it is retained for purposes other than provision in the customer account or must be retained for legal reasons (e.g. internal storage of customer data, order processes or invoices). It is the responsibility of the customers to back up their data upon termination of the customer account; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
- Watch list/ wish list: Customers can create a product list/wish list. In this case, the products are stored within the scope of the fulfilment of our contractual obligations until the account is deleted, unless the product list entries are removed by the customer or we expressly inform the customer of differing storage periods; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
- Online shop, order forms, e-commerce and delivery: We process the data of our customers in order to enable them to select, purchase or order the chosen products, goods and related services, as well as to enable their payment and delivery or performance. Where necessary for the execution of an order, we use service providers, in particular postal, freight forwarding and shipping companies, in order to carry out the delivery or performance to our customers. For the handling of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the course of the ordering or comparable purchasing process and comprises the information needed for delivery or provision and invoicing, as well as contact information in order to be able to consult with the customer if necessary; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Use of Online Platforms for Offering and Sales Purposes
We offer our services on online platforms operated by other service providers. In this context, the privacy notices of the respective platforms apply in addition to our privacy notices. This applies in particular with regard to the execution of the payment process and the procedures used on the platforms for reach measurement and interest-based marketing.
- 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Marketing.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- shopify: Platform via which e-commerce services are offered and carried out. The services and the processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment transactions, customer communication as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.shopify.com/de/. Privacy policy: https://www.shopify.com/de/legal/datenschutz.
Providers and Services Used in the Course of Business Activities
In the course of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers ("services" for short) in compliance with the statutory requirements. Their use is based on our interests in the proper, lawful and economically efficient management of our business operations and our internal organisation.
- 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); content data (e.g. entries in online forms). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Customers; prospective customers; users (e.g. website visitors, users of online services); business and contractual partners. Employees (e.g. staff, applicants, former employees).
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- DATEV: Software for accounting, communication with tax advisers and authorities, and with document storage; Service provider: DATEV eG, Paumgartnerstr. 6 - 14, 90429 Nürnberg, Germany; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/. Data processing agreement: Provided by the service provider.
- PageFly: Support in the creation and optimisation of Shopify shops and associated websites; Service provider: BraveBits JSC., 2th floor Ecolife Capitol, 58 To Huu, Me Tri, Nam Tu Liem District, Hanoi, Vietnam 100000; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://pagefly.io/; Privacy policy: https://pagefly.io/pages/privacy-policy. Basis for third-country transfers: Adequacy decision (United Kingdom).
Payment Methods
Within the framework of contractual and other legal relationships, on the basis of statutory obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, use further service providers in addition to banks and credit institutions (collectively "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract-related, amount-related and recipient-related information. This information is required in order to carry out the transactions. However, the data entered is processed only by the payment service providers and stored with them. This means that we do not receive any account-related or credit card-related information, but merely information confirming the payment or indicating that it was declined. Under certain circumstances, the data is transmitted by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the general terms and conditions and the privacy notices of the payment service providers.
Payment transactions are subject to the terms and conditions and the privacy notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and for the assertion of rights of withdrawal, rights of access 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 the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Contact data (e.g. e-mail, telephone numbers).
- Data subjects: Customers. Prospective customers.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Further information on processing operations, procedures and services:
- American Express: Payment services (technical integration of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.americanexpress.com/de/. Privacy policy: https://www.americanexpress.com/de-de/firma/legal/datenschutz-center/online-datenschutzerklarung/.
- Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Google Pay: Payment services (technical integration of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy policy: https://policies.google.com/privacy.
- Klarna: Payment services (technical integration of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.klarna.com/de. Privacy policy: https://www.klarna.com/de/datenschutz.
- Mastercard: Payment services (technical integration of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
- PayPal: Payment services (technical integration 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 bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Shop Pay (Shopify): Payment services (technical integration of online payment methods); Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
- Visa: Payment services (technical integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR); Website: https://www.visa.de; Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html. Basis for third-country transfers: Adequacy decision (UK).
Provision of the Online Offering and Web Hosting
We process users' data in order to be able to make our online services available to them. For this purpose, we process the user's IP address, which is necessary in order to transmit the content and functions of our online services to the user's browser or end device.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers etc.)). Security measures.
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Provision of the online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a "web host"); Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volumes of data transferred, notification of successful access, the browser type and version, the user's operating system, the referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.
Use of Cookies
Cookies are small text files or other storage markers that store information on end devices and read information from end devices, e.g. in order to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies may furthermore be used for various purposes, e.g. for the purposes of the functionality, security and convenience of online offerings and for the creation of analyses of visitor flows.
Information on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not necessary where the storing and reading of the information, including cookies, is strictly necessary in order to provide users with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online offering, load balancing, security, the storage of users' preferences and choices, or similar purposes connected with the provision of the main and ancillary functions of the online offering requested by users. The revocable consent is clearly communicated to users and contains the information on the respective use of cookies.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data by means of cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of their data is the consent given. Otherwise, the data processed by means of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, where this takes place in the context of fulfilling our contractual obligations, where the use of cookies is necessary in order to fulfil our contractual obligations. We provide information on the purposes for which cookies are processed by us in the course of this privacy policy or as part of our consent and processing procedures.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device has been 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 user data collected by means of cookies may be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period may be up to two years.
General information on withdrawal of consent and objection (so-called "opt-out"): Users may withdraw the consent they have given at any time and object to the processing in accordance with the statutory requirements. For this purpose, users may, among other things, restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes may also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).
Further information on processing operations, procedures and services:
- Shopify: Platform via which e-commerce services are offered and carried out. The services and the processes carried out in connection with them include, in particular, online shops, websites, their offers and content, community elements, purchase and payment transactions, customer communication as well as analysis and marketing; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
- Processing of cookie data on the basis of consent: We use a consent management solution by means of which users' consent to the use of cookies, or to the procedures and providers named within the consent management solution, is obtained. This procedure serves to obtain, log, manage and withdraw consents, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users' end devices. Within the framework of this procedure, users' consents are obtained for the use of cookies and the associated processing of information, including the specific processing operations and providers named in the consent management procedure. Users also have the option of managing and withdrawing their consents. The declarations of consent are stored in order to avoid a repeated query and to be able to provide proof of consent in accordance with the statutory requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Where no specific information on the providers of consent management services is available, the following general information applies: The consent is stored for a period of up to two years. In this context, a pseudonymous user identifier is created, which is stored together with the time of consent, the information on the scope of the consent (e.g. the relevant categories of cookies and/or service providers) and information about the browser, the system and the end device used; Legal bases: Consent (Art. 6(1)(a) GDPR).
Contact and Enquiry Management
When you contact us (e.g. by post, contact form, e-mail, telephone or via social media) and within the framework of existing user and business relationships, the details of the enquiring persons are processed to the extent that this is necessary to respond to the contact enquiries and any requested measures.
- 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners.
- Purposes of processing: Contact enquiries and communication; managing and responding to enquiries; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness. Direct marketing (e.g. by e-mail or by post).
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: When users contact us via our contact form, e-mail or other means of communication, we process the data provided to us in this context in order to handle the matter communicated; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
- Mailchimp: E-mail marketing, automation of marketing processes, collection. Storage and management of contact data, measurement of campaign performance, recording and analysis of recipients' interaction with content, personalisation of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
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Missive: Software for contact, enquiry and process support (multi-channel communication, i.e. management of enquiries from various channels, sales, process management, analyses and feedback functions); Service provider: Heliom inc., 95 rue St-Joseph Est, studio 205, Quebec, QC, Canada, G1K 3A6; Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR); Website: thttps://missiveapp.com/
; Privacy policy: https://missiveapp.com/privacy; Data processing agreement: Provided by the service provider; Basis for third-country transfers: Adequacy decision (Great Britain). Further information: Security measures: https://missiveapp.com/security.
Cloud Services
We use software services that are accessible via the internet and run on the servers of their providers (so-called "cloud services", also referred to as "Software as a Service") for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients, or publication of content and information).
In this context, personal data may be processed and stored on the providers' servers insofar as they form part of communication processes with us or are otherwise processed by us as set out in this privacy policy. These data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata, which they use for security purposes and for service optimisation.
Where we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users' devices for the purposes of web analytics or in order to remember users' settings (e.g. in the case of media control).
- 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Customers; employees (e.g. staff, applicants, former employees); prospective customers. Communication partners.
- Purposes of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers etc.).).
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Microsoft cloud services: Cloud storage, cloud infrastructure services and cloud-based application software; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Irland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter; Data processing agreement: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third-country transfers: Data Privacy Framework (DPF).
Newsletters and Electronic Notifications
We send newsletters, e-mails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or where permitted by law. Where the contents of the newsletter are specifically described in the course of a newsletter registration, they are decisive for the users' consent. In all other respects, our newsletters contain information about our services and about us.
In order to subscribe to our newsletters, it is generally sufficient for you to provide your e-mail address. We may, however, ask you to provide a name, for the purpose of addressing you personally in the newsletter, or further details where these are necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter generally takes place by means of a so-called double opt-in procedure. This means that, after registering, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register using e-mail addresses belonging to others. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and the time of confirmation as well as the IP address. Changes to your data stored with the mailing service provider are likewise logged.
Erasure and restriction of processing: We may store unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before we erase them, in order to be able to prove consent that was formerly given. The processing of these data is restricted to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. Where there are obligations to observe objections permanently, we reserve the right to store the e-mail address in a block list (so-called "blocklist") solely for this purpose.
The logging of the registration procedure takes place on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g. by e-mail or by post).
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
- Right to object (opt-out): You may cancel the receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link for cancelling the newsletter either at the end of each newsletter, or you may otherwise use one of the contact options stated above, preferably e-mail, for this purpose.
Further information on processing operations, procedures and services:
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Measurement of open and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, where we use a mailing service provider, from that provider's server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or of the target groups and their reading behaviour based on their retrieval locations (which can be determined with the aid of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until these are erased. The evaluations serve to enable us to recognise the reading habits of our users and to adapt our content to them or to send different content in accordance with the interests of our users.
The measurement of open rates and click rates, the storage of the measurement results in the users' profiles and their further processing take place on the basis of the users' consent.
Unfortunately, it is not possible to withdraw consent to the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be erased; Legal bases: Consent (Art. 6(1)(a) GDPR). - Mailchimp: E-mail marketing, automation of marketing processes, collection. Storage and management of contact data, measurement of campaign performance, recording and analysis of recipients' interaction with content, personalisation of content; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: Special security measures: https://mailchimp.com/de/help/mailchimp-european-data-transfers/.
Prize Draws and Competitions
We process personal data of participants in prize draws and competitions only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, execution and handling of the prize draw, the participants have consented to the processing, or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through the possible recording of IP addresses when prize draw entries are submitted).
If entries by participants are published in the course of the prize draws (e.g. in the context of a vote or presentation of the prize draw entries or of the winners, or of reporting on the prize draw), we point out that the names of the participants may also be published in this context. Participants may object to this at any time.
If the prize draw takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and privacy policies of the respective platforms apply in addition. In these cases, we point out that we are responsible for the information provided by participants in the course of the prize draw and that enquiries regarding the prize draw are to be addressed to us.
The participants' data will be erased as soon as the prize draw or competition has ended and the data are no longer required in order to inform the winners or because queries regarding the prize draw are no longer to be expected. As a general rule, participants' data will be erased no later than 6 months after the end of the prize draw. Winners' data may be retained for longer, e.g. in order to be able to answer queries regarding the prizes or to fulfil the prizes; in this case, the retention period depends on the type of prize and is, for example, up to three years in the case of goods or services, e.g. in order to be able to handle warranty cases. Furthermore, participants' data may be stored for longer, e.g. in the form of reporting on the prize draw in online and offline media.
Where data were also collected for other purposes in the course of the prize draw, their processing and the retention period are governed by the privacy information relating to that use (e.g. in the case of a newsletter registration in the course of a prize draw).
- Types of data processed: Inventory data (e.g. names, addresses); content data (e.g. entries in online forms). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Participants in prize draws and competitions.
- Purposes of processing: Conducting prize draws and competitions.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Surveys and Polls
We conduct surveys and polls in order to collect information for the respective communicated purpose of the survey or poll. The surveys and polls conducted by us (hereinafter "surveys") are evaluated anonymously. Personal data are processed only insofar as this is necessary for the provision and technical execution 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Communication partners. Participants.
- Purposes of processing: Feedback (e.g. collecting feedback via online form).
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Web analytics, monitoring and optimisation
Web analytics (also referred to as "reach measurement") serves to evaluate the visitor flows of 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 reach analysis, we can, for example, identify at what time our online offering or its functions or content are used most frequently or invite re-use. Likewise, we can understand which areas require 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.
Unless otherwise stated below, profiles, i.e. data combined in relation to a usage process, may be created for these purposes and information may be stored in a browser or on a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information, such as the browser used, the computer system used and information on usage times. Where users have consented to the collection of their location data vis-à-vis us or vis-à-vis the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by truncating the IP address) to protect users. In general, no clear data of users (such as e-mail addresses or names) are stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Remarketing; target group formation; reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); click tracking; A/B tests; feedback (e.g. collecting feedback via online form); heatmaps (mouse movements on the part of users which are combined into an overall picture.); marketing. Provision of our online offering and user-friendliness.
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6(1)(a) GDPR).
Further information on processing operations, procedures and services:
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Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It serves to assign analysis information to a terminal device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, whether they have accessed these again or whether they have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offering and technical aspects of their terminal devices and browsers.
In doing so, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographical location data by deriving the following metadata from IP addresses: city (and the derived latitude and longitude of the city), continent, country, region, subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocation data before being deleted immediately. They are not logged, are not accessible and are not used for any further purposes. When Google Analytics collects measurement data, all IP lookups are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and of the data processed). - Google Signals (Google Analytics function): Google Signals are session data from websites and apps that Google associates with users who have signed in to their Google accounts and have activated ads personalisation. This association of data with these signed-in users is used to enable cross-device reporting, cross-device remarketing and cross-device conversion measurement. These include: cross-platform reports - linking of data about devices and activities from different sessions using your User ID or Google Signals data, which enable an understanding of user behaviour at every step of the conversion process, from first contact to conversion and beyond; remarketing with Google Analytics - creation of remarketing audiences from Google Analytics data and sharing of these audiences with linked advertising accounts; demographics and interests - Google Analytics collects additional information about demographic data and interests of users who are signed in to their Google accounts and have activated ads personalisation; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://support.google.com/analytics/answer/7532985?hl=de; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://business.safety.google/adsservices/ (types of processing and of the data processed).
- Target group formation with Google Analytics: We use Google Analytics in order to display the advertisements placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interests in certain topics or products which are determined on the basis of the websites visited) which we transmit to Google (so-called "remarketing audiences" or "Google Analytics audiences"). With the help of remarketing audiences, we also wish to ensure that our advertisements correspond to the potential interest of the users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Legal bases: https://business.safety.google/adsprocessorterms/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and of the data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
- Mouseflow: The data processing serves the purpose of analysing websites and their visitors (heatmaps and click tracking). For this purpose, cookies may be used and user profiles may be created. In the process, a log of mouse movements and clicks is created with the intention of replaying individual website visits on a random sample basis and deriving potential improvements for the website from them. The data collected with Mouseflow will not be used to identify the user personally without the separately granted consent of the user and will not be merged with personal data about the bearer of the pseudonym; Service provider: Mouseflow ApS, Flaesketorvet 68, 1711 Copenhagen, Denmark; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://mouseflow.com/de/; Privacy policy: https://mouseflow.com/legal/visitor/. Option to object (opt-out): https://mouseflow.com/de/opt-out/.
- Google Universal Analytics: Reach measurement and web analytics - We use Universal Analytics, a version of Google Analytics, to carry out a user analysis on the basis of a pseudonymous user identification number. This identification number does not contain any clear data, such as names or e-mail addresses. It serves to assign analysis information to a user, e.g. in order to recognise which content users have accessed within a usage process or whether they access our online offering again. In doing so, pseudonymous profiles of users are created with information from the use of various devices; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Terms and conditions: https://business.safety.google/adsprocessorterms/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Basis for third-country transfers: Data Privacy Framework (DPF); Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and of the data processed).
Online Marketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on the potential interests of users, as well as the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie"), or similar procedures are used by means of which the information about the user that is relevant for the display 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, this data may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as e-mail addresses or names) is stored in the context of the online marketing procedures, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is generally stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure, analysed for the purposes of displaying content, supplemented with further data and stored on the server of the online marketing procedure provider.
By way of exception, clear data may be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g. by giving consent as part of the registration process.
As a matter of principle, we only receive access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
- Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); event data (Facebook) ("event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixel (via apps or by other means), and that 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 comments written), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted); contact information (Facebook) ("contact information" is data that (clearly) identifies data subjects, such as names, e-mail addresses and telephone numbers, which can be transmitted to Facebook, e.g. via Facebook pixel or upload for matching purposes for the purpose of creating Custom Audiences. After the matching for the purpose of creating target groups, the contact information is deleted).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest-based/behavioural profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles); provision of our online services and user-friendliness; remarketing. Click tracking.
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
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Option to object (opt-out): We refer to the privacy notices of the respective providers and the options to object indicated for the providers (so-called "opt-out"). If no explicit opt-out option has been indicated, you have, on the one hand, the option of disabling cookies in the settings of your browser. However, this may restrict functions of our online services. We therefore additionally recommend the following opt-out options, which are offered collectively for the respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Further information on processing operations, procedures and services:
- Meta pixel and target group formation (Custom Audiences): With the help of the Meta pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), the company Meta is, on the one hand, able to determine the visitors to our online services as a target group for the display of advertisements (so-called "Meta ads"). Accordingly, we use the Meta pixel in order to display the Meta ads placed by us only to those users on Meta's platforms and within the services of the partners cooperating with Meta (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online services or who exhibit certain characteristics (e.g. interest in certain topics or products that become apparent from the websites visited) which we transmit to Meta (so-called "Custom Audiences"). With the help of the Meta pixel, we also want to ensure that our Meta ads correspond to the potential interest of the users and are not perceived as a nuisance. With the help of the Meta pixel, we can furthermore track the effectiveness of the Meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Meta ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Event data of users, i.e. behavioural and interest information, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Advanced matching for the Meta pixel: In addition to the processing of event data in the context of the use of the Meta pixel (or comparable functions, e.g. in apps), contact information (data identifying individual persons, such as names, e-mail addresses and telephone numbers) is also collected by Meta within our online services or transmitted to Meta. The processing of the contact information serves the formation of target groups (so-called "Custom Audiences") for a display of content and advertising information that is oriented towards the presumed interests of the users. The collection, or rather the transmission and matching with data held by Meta, does not take place in plain text, but as so-called "hash values", i.e. mathematical representations of the data (this method is used, for example, when storing passwords). After the matching for the purpose of creating target groups, the contact information is deleted; Legal bases: Consent (Art. 6(1)(a) GDPR); Privacy policy: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Data processing agreement: https://www.facebook.com/legal/terms/dataprocessing; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://www.facebook.com/legal/terms/data_security_terms.
- Facebook advertisements: Placement of advertisements within the Facebook platform and evaluation of the advertisement results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Option to object (opt-out): We refer to the privacy and advertising settings in the users' profile on the Facebook platforms as well as to Facebook's consent procedures and contact options for exercising rights of access and other data subject rights, as described in Facebook's privacy policy; Further information: Event data of users, i.e. behavioural and interest information, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Google Ads and conversion measurement: Online marketing procedure for the purpose of placing content and advertisements within the advertising network of the service provider (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the advertisements. In addition, we measure the conversion of the advertisements, i.e. whether the users have taken them as an occasion to interact with the advertisements and to make use of the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and of the data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology by which users who use an online service are included in a pseudonymous remarketing list so that advertisements can be displayed to the users on other online services on the basis of their visit to the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and of the data processed: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
- Enhanced conversions for Google Ads: When customers click on our Google advertisements and subsequently make use of the advertised service (so-called "conversion"), the data entered by the user, such as the e-mail address, the name, the residential address or the telephone number, may be transmitted to Google. The hash values are then matched with existing Google accounts of the users in order to be able to better evaluate and improve the interaction of the users with the advertisements (e.g. clicks or views) and thus their performance; Legal bases: Consent (Art. 6(1)(a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- Instagram advertisements: Placement of advertisements within the Instagram platform and evaluation of the advertisement results; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Option to object (opt-out): We refer to the privacy and advertising settings in the users' profile on the Instagram platform as well as, in the context of Instagram's consent procedures, to Instagram's contact options for exercising rights of access and other data subject rights in Instagram's privacy policy; Further information: Event data of users, i.e. behavioural and interest information, is processed for the purposes of targeted advertising and target group formation on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
- Outbrain: Display of personalised advertisements; Service provider: Outbrain United Kingdom Limited, 175 High Holborn, London WC1V 7AA, United Kingdom; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.outbrain.com; Privacy policy: https://www.outbrain.com/privacy/. Erasure of data: The stored personal data is erased or anonymised after 13 months.
- UTM parameters: Analysis of sources and user actions on the basis of an extension of web addresses referring to us with an additional parameter, the "UTM" parameter. For example, a UTM parameter "utm_source=plattformX &utm_medium=video" can tell us that a person clicked on the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. posting, link, image and video). With the help of this information, we can, for example, review our visibility on the internet or the effectiveness of our campaigns; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
- TikTok Pixel: Code that is loaded when a user visits our online services and that tracks the behaviour and conversions of the user and stores them in a profile (possible purposes of use: measurement of campaign performance, optimisation of ad delivery, building of custom and lookalike audiences); Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://ads.tiktok.com/help/article/tiktok-pixel. Privacy policy: https://www.tiktok.com/de/privacy-policy.
- Tiktok advertisements: Placement of advertisements within the Tiktok platform and evaluation of the advertisement results; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.tiktok.com/business/. Privacy policy: https://www.tiktok.com/de/privacy-policy.
Presences on Social Networks (Social Media)
We maintain online presences within social networks and, in this context, process data of users in order to communicate with the users active there or to offer information about us.
We point out that, in doing so, data of users may be processed outside the territory of the European Union. This may give rise to risks for users because, for example, the enforcement of users' rights could be made more difficult.
Furthermore, the data of users within social networks is generally processed for market research and advertising purposes. For example, usage profiles may be created on the basis of user behaviour and the resulting interests of the users. The usage profiles may in turn be used, for example, to place advertisements inside and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the users' computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the usage profiles independently of the devices used by the users (in particular, 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 options to object (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, too, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users in each case and can take appropriate measures and provide information directly. Should you nevertheless 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 and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
- Facebook pages: Profiles within the social network Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content that 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 the 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 in order to provide analytics services, so-called "Page Insights", to page operators so that they gain insights into how people interact with their pages and with the content associated with them. We have concluded a special agreement with Facebook ("Information about Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which in particular governs which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, address requests for information or erasure directly to Facebook). The rights of users (in particular to information, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company established in the EU. The 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.
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LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF); Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors that is collected for the purposes of creating the "Page Insights" (statistics) of our LinkedIn profiles.
This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and details from the users' profiles, such as job function, country, industry, seniority level, company size and employment status. Privacy information on the processing of users' data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
We have concluded a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which in particular governs which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the data subject rights (i.e. users can, for example, address requests for information or erasure directly to LinkedIn). The rights of users (in particular to information, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of the data by and the transfer to the Ireland Unlimited Company, a company established in the EU. The further processing of the data is the exclusive responsibility of the Ireland Unlimited Company, which concerns in particular the transfer of the data to the parent company LinkedIn Corporation in the USA. - Pinterest: Social network; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pinterest.com. Privacy policy: https://policy.pinterest.com/de/privacy-policy.
- TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.tiktok.com. Privacy policy: https://www.tiktok.com/de/privacy-policy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Option to object (opt-out): https://myadcenter.google.com/personalizationoff.
Plugins and Embedded Functions and Content
We integrate functional and content elements into our online offering 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").
Integration always requires that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to the users' browsers. The IP address is therefore required for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. By means of the "pixel tags", information such as visitor traffic on the pages of this website can be analysed. The pseudonymous information may also be stored in cookies on the users' device and may contain, among other things, technical information about the browser and the operating system, referring websites, the time of the visit and other details about the use of our online offering, and may also be combined with such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); 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 can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or by other means), and that relates to persons or their actions; the data includes, e.g., 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 forming target groups for content and advertising information (Custom Audiences). Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, e-mail addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups formed from it are deleted upon the deletion of our Facebook account).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; marketing. Profiles with user-related information (creation of user profiles).
- Legal bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from the servers of other providers (e.g. function libraries that we use for the purpose of displaying our online offering or making it user-friendly). In doing so, the respective providers collect the IP address of the users and may process it for the purposes of transmitting the software to the users' browser, for security purposes, and for the analysis and optimisation of their services. - We integrate software into our online offering that we retrieve from the servers of other providers (e.g. function libraries that we use for the purpose of displaying our online offering or making it user-friendly). In doing so, the respective providers collect the IP address of the users and may process it for the purposes of transmitting the software to the users' browser, for security purposes, and for the analysis and optimisation of their services; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
- Facebook plugins and content: Facebook social plugins and content - This may include, e.g., content such as images, videos or texts and buttons with which users can share content of this online offering within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible, together with Meta Platforms Ireland Limited, for the collection or receipt in the course of a transmission (but not the further processing) of "event data" which Facebook collects by means of the Facebook social plugins (and content embedding functions) that are executed on our online offering, or receives in the course of a transmission, for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of the users; b) delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improvement of ad delivery and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which 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, e.g., address requests for information or erasure directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, 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 access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
- Google Fonts (retrieval from the Google server): Retrieval of fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to being up to date and loading times, their uniform display and the consideration of possible restrictions under licensing law. 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) is transmitted which is 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 offering, the users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) of Google Fonts and subsequently the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e. the web page on which 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 the HTTP requests (requested URL, user agent and referrer 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 adapt the font that is generated for the respective browser type. The user agent is logged primarily for debugging and is used to generate aggregated usage statistics with which the popularity of font families is measured. These aggregated usage statistics are published on the "Analytics" page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations can be generated based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to serve targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). 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 the users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
- Instagram plugins and content: Instagram plugins and content - This may include, e.g., content such as images, videos or texts and buttons with which users can share content of this online offering within Instagram. - We are jointly responsible, together with Meta Platforms Ireland Limited, for the collection or receipt in the course of a transmission (but not the further processing) of "event data" which Facebook collects by means of functions of Instagram (e.g. content embedding functions) that are executed on our online offering, or receives in the course of a transmission, for the following purposes: a) display of content and advertising information that corresponds to the presumed interests of the users; b) delivery of commercial and transaction-related messages (e.g. addressing users via Facebook Messenger); c) improvement of ad delivery and personalisation of functions and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of the users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which 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, e.g., address requests for information or erasure directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information on individual users and are anonymous to us), this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, 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 access, erasure, objection and to lodge a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy/.
- Pinterest plugins and content: Pinterest plugins and content - This may include, e.g., content such as images, videos or texts and buttons with which users can share content of this online offering within Pinterest; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.pinterest.com. Privacy policy: https://policy.pinterest.com/de/privacy-policy.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff.
- TikTok plugins and content: TikTok plugins and content - This may include, e.g., content such as images, videos or texts and buttons; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.tiktok.com. Privacy policy: https://www.tiktok.com/legal/privacy-policy?lang=de.
Management, Organisation and Support Tools
We use services, platforms and software from other providers (hereinafter referred to as "third-party providers") for the purposes of organising, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the statutory requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. This may affect various data which we process in accordance with this privacy policy. Such data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.
Where users are referred to the 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, for service optimisation or for marketing purposes. We therefore ask you to observe the privacy notices of the respective third-party providers.
- Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); inventory data (e.g. names, addresses). Contact data (e.g. e-mail, telephone numbers).
- Data subjects: Communication partners. Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).
- Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Further information on processing operations, procedures and services:
- Bitly: URL shortening service and link management platform; Service provider: Bitly, Inc., 139 Fifth Avenue, 5th Floor, New York, NY 10010, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://bitly.com; Privacy policy: https://bitly.com/pages/privacy. Basis for third-country transfers: Data Privacy Framework (DPF).
- ChatGPT: AI-based service designed to understand and generate natural language and related inputs and data, to analyse information and to make predictions ("AI", i.e. "artificial intelligence", is to be understood in the applicable legal sense of the term); Service provider: OpenAI Ireland Ltd, 117-126 Sheriff Street Upper, D01 YC43 Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://openai.com/product; Privacy policy: https://openai.com/de/policies/eu-privacy-policy. Option to object (opt-out): https://docs.google.com/forms/d/e/1FAIpQLSevgtKyiSWIOj6CV6XWBHl1daPZSOcIWzcUYUXQ1xttjBgDpA/viewform.
- Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://miro.com/; Privacy policy: https://miro.com/legal/privacy-policy/; Data processing agreement: https://miro.com/legal/vendor-data-processing-addendum/. Basis for third-country transfers: Standard contractual clauses (https://miro.com/legal/vendor-data-processing-addendum/).
- WeTransfer: Transfer of files via the internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Legal bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://wetransfer.com. Privacy policy: https://wetransfer.com/legal/privacy.
Changes and Updates to the Privacy Policy
We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to 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 any other individual notification.
Where we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time, and we ask you to verify the information before contacting them.
Definitions of Terms
This section provides you with an overview of the terms used in this privacy policy. Where the terms are defined by law, their statutory definitions apply. The following explanations, by contrast, are intended primarily to aid understanding.
- A/B tests: A/B tests serve to improve the user-friendliness and performance of online offerings. For example, users are shown different versions of a website or its elements, such as input forms, on which the placement of the content or the labelling of the navigation elements may differ. Subsequently, on the basis of the users' behaviour, e.g. longer stays on the website or more frequent interaction with the elements, it can be determined which of these websites or elements better meet the needs of the users.
- Heatmaps: "Heatmaps" are mouse movements of users which are combined into an overall picture, with the help of which it can be recognised, for example, which website elements are preferred and which website elements users prefer less.
- Click tracking: Click tracking makes it possible to keep an overview of users' movements within an entire online offering. Since the results of these tests are more accurate if the users' interaction can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are generally stored on the users' computers for these test purposes.
- Conversion measurement: Conversion measurement (also referred to as "visit action evaluation") is a procedure by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is generally stored on the users' devices within the websites on which the marketing measures take place and is then retrieved again on the target website. In this way we can, for example, track whether the advertisements placed by us on other websites were 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.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, comprises any form of automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are frequently used for profiling purposes.
- Reach measurement: Reach measurement (also referred to as web analytics) serves to evaluate the visitor flows of an online offering and may include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offerings can recognise, for example, at what time users visit their websites and which content they are interested in. This enables them, for example, to better adapt the content of the websites to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
- Remarketing: The terms "remarketing" or "retargeting" are used when, for example, it is noted for advertising purposes 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.
- Location data: Location data is generated when a mobile device (or another device with the technical prerequisites for determining location) connects to a radio cell, a Wi-Fi network or similar technical means and functions for determining location. Location data serves 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 location-dependent information.
- Tracking: The term "tracking" is used when the behaviour of users can be traced across several online offerings. As a rule, behavioural and interest information with regard to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can subsequently be used, for example, to display advertisements to users which are likely to correspond to their interests.
- Controller: "Controller" means 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 on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
- Target group formation: The term target group formation ("Custom Audiences") is used when target groups are determined for advertising purposes, e.g. the display of advertisements. For example, on the basis of 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 for the online shop in which he or she viewed the products. "Lookalike Audiences" (or similar target groups), in turn, refers to cases where the content deemed suitable is displayed to users whose profiles or interests presumably correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used for the purposes of creating Custom Audiences and Lookalike Audiences.

