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Privacy policy

Introduction

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

The terms used are not gender specific.

Status: October 31, 2021

Table of contents

Responsible

PUREPROGRESS GmbH
Zollikerstr. 153
8008 Zurich
Switzerland

Authorized representatives: Alexander Haile.

E-mail address: info@pureprogress.ch.

Imprint: https://pureprogress.ch/impressum.

Processing overview

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

Types of data processed

  • Event Data (Facebook) („Event Data“ is data that may be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or other means), and relates to individuals or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the Event Data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences).Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Inventory data (e.g., names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants concerning their person or qualifications).
  • Content data (e.g. entries in online forms).
  • Contact information (e.g., email, phone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. web pages visited, interest in content, access times).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of persons concerned

  • Employees (e.g., employees, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Clients.
  • Users (e.g., website visitors, users of online services).

Processing purposes

  • Assessment of creditworthiness and credit standing.
  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Office and organizational procedures.
  • Content Delivery Network (CDN).
  • Direct marketing (e.g., via e-mail or postal mail).
  • Target group formation.
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Administration and response to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (1) p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 (2) (b) GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 (2) (b ) GDPR are collected during the application procedure. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from job applicants in order for the controller or the data subject to exercise his or her rights under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (1) GDPR. 2 lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to. Art. 9 par. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to. Art. 9 par. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

National data protection regulations in Switzerland: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Switzerland. This includes, in particular, the Federal Data Protection Act (DSG). The DPA applies in particular if no EU/EEC citizens are involved and, for example, only data of Swiss citizens is processed.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, ensuring the availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other entities, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

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

As part of our privacy notices, we may provide users with additional information regarding the deletion as well as the retention of data that is specific to each processing operation.

Cookies use

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

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g., to store logins or other user input or for security reasons).
  • Statistics, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user’s interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also called „tracking“, i.e., following the potential interests of users. Insofar as we use cookies or „tracking“ technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: If we do not provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as „opt-out“). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes may also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure under which users‘ consents to the use of cookies, or to the processing operations and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored so that it does not have to be repeated and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system, and end device used.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as „contractual partners“) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Agency Services: We process our customers‘ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services.

Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as „clients“) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

If it is necessary for the fulfillment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Brokerage and Intermediary Services: We process the data of our customers, clients and prospective customers (uniformly referred to as „customers“) in accordance with the underlying mandate of the customers. We may also process the information on the characteristics and circumstances of persons or things belonging to them, if this is part of the subject of our order. This may include, for example, information on personal circumstances, movable or immovable tangible property, and financial situation.

If required for the fulfillment of the contract or required by law or approved by the customer or based on our legitimate interests, we disclose or transmit the data of the customers in the context of coverage requests, conclusions and the settlement of contracts to providers of the mediated services / objects, insurers, reinsurers, broker pools, technical service providers, other service providers, such as cooperating associations, as well as financial service providers, credit institutions and investment companies, as well as social insurance carriers, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin).e.g. cooperating associations, as well as financial service providers, credit institutions and investment companies, as well as social insurance institutions, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin). Furthermore, subject to other agreements, we may engage subcontractors, such as sub-brokers.

Legal advice: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as „clients“) in order to be able to provide them with our contractual or pre-contractual services, in particular advisory services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and mandate relationship.

If we have the consent of the client, if it is required for the fulfillment of our contract, by law or for the protection of vital interests, or if it is based on our legitimate interests in the efficient and safe performance of our activities, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts or in the area of IT, office or comparable services, in compliance with the requirements of professional law.

Business consulting: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as „customers“) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.

If it is necessary for the fulfillment of our contract or required by law, or if we have the customers‘ consent, we disclose or transfer the customers‘ data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

  • Types of data processed: inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., e-mail, telephone numbers), contract data (e.g., subject matter of contract, term, customer category).
  • Data subjects: Prospective customers, business and contractual partners, clients, customers.
  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to requests.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Sales via online marketplaces and platforms

We offer our services on online platforms operated by other service providers. In this context, the data protection notices of the respective platforms apply in addition to our data protection notices. This applies in particular with regard to the execution of the payment process and the methods 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 contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers.
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Payment method

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions for this purpose (collectively, „payment service providers“).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is necessary to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the GTC and the data protection information of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, shall apply to the payment transactions. We also refer to these for further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, interested parties.
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from service companies specializing in this area (credit agencies) in order to protect our legitimate interests.

We process the information received from credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

In accordance with Art. 22 DSGVO, the decision as to whether we provide advance services is made solely on the basis of an automated decision in the individual case, which is made by our software on the basis of the information provided by the credit agency.

Insofar as we obtain express consent from contractual partners, the legal basis for the credit check and the transmission of the customer’s data to the credit agencies is the consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the default security of our payment claims.

  • Types of data processed: inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contact data (e.g., e-mail, telephone numbers), contract data (e.g., subject matter of contract, term, customer category).
  • Data subjects: Customers, prospective customers.
  • Purposes of processing: assessment of creditworthiness and credit standing.
  • Legal bases: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Automated decisions in individual cases: credit information (decision based on a credit check).

Services used and service providers:

Provision of the online offer and web hosting

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

The data processed in the course of providing the hosting service may include all information concerning the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.

Content Delivery Network: We use a content delivery network (CDN). A CDN is a service with the help of which the content of an online offering, in particular large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • 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 data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness, content delivery network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter „publication medium“). Readers‘ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

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

Furthermore, we reserve the right to process the user’s data for the purpose of spam detection on the basis of our legitimate interests.

On the same legal basis, in the case of surveys, we reserve the right to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.

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

Retrieval of WordPress emojis and smilies: Within our WordPress blog, graphical emojis (or smilies), i.e., small graphic files expressing emotions, are used for purposes of efficient integration of content elements, obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users‘ browsers.

Akismet anti-spam check: We use the „Akismet“ service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. For this purpose, all comment data is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.

Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we don’t see any alternatives that work just as effectively.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contract data (e.g. subject matter of contract, term, customer category).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: providing contractual services and customer service, feedback (e.g. collecting feedback via online form), security measures, managing and responding to requests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Contact and request management

When contacting us (e.g. by contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The answering of contact inquiries as well as the administration of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of legitimate interests in answering inquiries and maintaining user or business relationships.

  • 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).
  • Data subjects: Communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Communication via messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.

You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages is not viewable, not even by the messenger providers themselves. You should always use an up-to-date version of messengers with encryption enabled to ensure that message content is encrypted.

However, we additionally point out to our communication partners that the providers of the messengers cannot view the content, but can learn that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, on their own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

Revocation, objection and deletion: You can revoke a given consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations.

Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer requests via Messenger. This is the case if, for example, contractual internals require special secrecy or a reply via Messenger does not meet formal requirements. In such cases, we refer you to more adequate communication channels.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. entries in online forms).
  • Affected persons: Communication partners.
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Application procedure

The application process requires that applicants provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

Basically, the required information includes personal information, such as the name, address, a way to contact you, as well as evidence of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

If provided, applicants may submit their applications to us using an online form. The data is transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. However, please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. Therefore, we cannot take responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of applicant search, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services of third-party providers in compliance with legal requirements.

Applicants are welcome to contact us regarding the method of application submission or to send us the application by mail.

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from job applicants in order for the controller or the data subject to exercise his or her rights under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to. Art. 9 par. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for health or social care or treatment or for the management of health or social care systems and services pursuant to. Art. 9 par. 2 lit. h. GDPR. In the case of communication of the special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants‘ data will be deleted. Applicants‘ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified revocation by the applicants, the deletion takes place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Affected Persons: Applicants.
  • Purposes of the processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 (2) lit. b DSGVO).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called „cloud services“, also referred to as „software as a service“) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

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

If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on users‘ devices for the purposes of web analytics or to remember users‘ settings (e.g., in the case of media control).

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

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, employees (e.g., employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter „newsletter“) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the user’s consent. For the rest, our newsletters contain information about our services and us.

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

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in process. I.e., after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called „block list“) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purposes of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.

Notes on legal basis: The newsletter is sent on the basis of the recipients‘ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

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

Measurement of opening and click-through rates: The newsletters contain a so-called „web beacon“, i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether 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 they are deleted. We use the analyses to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The measurement of opening rates and click-through rates as well as the storage of the measurement results in the users‘ profiles and their further processing are based on the users‘ consent.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled, or it must be contradicted. In this case, the stored profile information will be deleted.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. web pages visited, interest in content, access times).
  • Data subjects: Communication partners.
  • Purposes of processing: direct marketing (e.g., by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Option to object (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent, or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Promotional communication via e-mail, mail, fax or telephone

We process personal data for the purposes of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to promotional communications at any time.

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Web analysis, monitoring and optimization

Web analytics (also referred to as „reach measurement“) is used to evaluate the flow of visitors to our online offering and may include behavior, 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 offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called „cookie“) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used, and information about usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking method (i.e., pseudonymization by shortening the IP address) to protect users. In general, the data stored in the context of web analytics, A/B testing and optimization is not clear user data (such as e-mail addresses or names), but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

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

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, „Content“) based on users‘ potential interests and measuring its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called „cookie“) or similar procedures are used, by means of which the user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, web pages visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of the users are also stored. However, we use available IP masking methods (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms are. This means that we, as well as the providers of the online marketing methods, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be read on other websites that use the same online marketing method and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing method provider.

Exceptionally, clear data can be assigned to profiles. This is the case if, for example, the users are members of a social network whose online marketing methods we use and the network links the users‘ profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

We generally only receive access to aggregate information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract being concluded with us. Conversion measurement is used solely to analyze the success of our marketing efforts.

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

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

We use the „Google Marketing Platform“ (and services such as „Google Ad Manager“) to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products he or she was interested in on other online offers, this is referred to as „remarketing“.

With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called „Facebook ads“). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called „Audience Network“). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the web pages visited) that we transmit to Facebook (so-called „Custom Audiences“). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called „conversion measurement“).

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) („event data“ is data that may be transmitted, e.g. via Facebook Pixel (via apps or in other ways), by us to Facebook and relates to individuals or their actions; the data includes, e.g.. Information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; 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 written comments), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: marketing, profiling with user-related information (creating user profiles), remarketing, targeting (determining target groups relevant for marketing purposes or other output of content), conversion measurement (measuring the effectiveness of marketing measures), targeting.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called „opt-out“) given to the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in summary form directed at respective areas: a) Europe: https://www.youronlinechoices.eu. (b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Inter-area: https://optout.aboutads.info.

Services used and service providers:

Customer reviews and evaluation process

We participate in review and rating processes to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or processes, the General Terms and Conditions of Business or Use and the data protection notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the evaluating persons have actually used our services, we transmit, with the customers‘ consent, the data required for this with regard to the customer and the service used to the respective evaluation platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

Rating widget: We integrate so-called „rating widgets“ into our online offer. A widget is a function and content element integrated into our online offer that displays changeable information. It can be represented, for example, in the form of a seal or comparable element, sometimes called a „badge“. In doing so, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offer to the widget provider’s server and the widget provider receives certain technical data (access data, including IP address) that are necessary so that the widget’s content can be delivered to the user’s browser.

Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

  • Types of data processed: contractual data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, users (e.g., website visitors, users of online services).
  • Purposes of processing: feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • Google Customer Reviews: Service for obtaining and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Terms and Conditions: https://support.google.com/merchants/topic/7259129?hl=de&ref_topic=7257954; Privacy Policy: https: //policies.google.com/privacyIn the context of obtaining customer reviews, an identification number as well as time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address as well as their country of residence information as well as the review information itself are processed; Further information on the types of processing as well as the processed data: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Presence in social networks (social media)

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

We would like to point out that in the process, user data may be processed outside the area of the European Union. This may give rise to risks for users because, for example, it could make it more difficult to enforce users‘ rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to display advertisements within and outside the networks that presumably correspond to the users‘ interests. For these purposes, cookies are usually stored on the users‘ computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users‘ data in each case and can take appropriate measures and provide information directly. If you still need help, then you can contact us.

Facebook pages: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (so-called „fan page“). This data includes information about the types of content users view or interact with, or the actions they take (see under „Things You and Others Do and Provide“ in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e. g. B. 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 Privacy Policy under „How do we use this information?“, Facebook also collects and uses information to provide analytics services, called „Page Insights,“ to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have concluded a special agreement with Facebook („Information on Page Insights“, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the „Information on Page Insights“(https://www.facebook.com/legal/terms/information_about_page_insights_data).

  • Types of data processed: contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • 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 basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Plugins and embedded functions and content

We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as „third-party providers“). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as „Content“).

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of these contents or functions. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. The „pixel tags“ can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offering, as well as being linked to such information from other sources.

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

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offer that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of presentation or user-friendliness of our online offer). In doing so, the respective providers collect the IP address of the users and may process it for purposes of transmitting the software to the user’s browser and for security purposes, as well as for evaluating and optimizing their offer.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

  • Google Fonts: We integrate the fonts („Google Fonts“) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https: //policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service „Google Maps“ of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed as part of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Maps APIs and SDKs: Interfaces to Google’s map and location services that allow, for example, supplementing address entries, location determinations, distance calculations or providing supplementary information on locations and other places; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/maps-platform; privacy policy: https: //policies.google.com/privacy.
  • reCAPTCHA: We integrate the „reCAPTCHA“ function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called „bots“). Processed data may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on web pages, previously visited web pages, interactions with ReCaptcha on other web pages, possibly cookies, and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; privacy policy: https: //policies.google.com/privacy; opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, organization and auxiliary tools

We use services, platforms and software of other providers (hereinafter referred to as „Third Party Providers“) for the purpose of organizing, managing, planning as well as providing our services. When selecting third-party providers and their services, we observe the legal requirements.

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

If 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, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

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

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact information for companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

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 at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to supervisory authority: In accordance with the law 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 where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions

This section provides you with an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined especially in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are sorted alphabetically.

  • Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Content Delivery Network (CDN): A „Content Delivery Network“ (CDN) is a service that can be used to deliver the content of an online offering, in particular large media files such as graphics or program scripts, more quickly and securely with the help of regionally distributed servers connected via the Internet.
  • IP masking: IP masking is a method of deleting the last octet, i.e., the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
  • Conversion measurement: Conversion measurement (also known as „visit action evaluation“) is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users‘ devices within the websites on which the marketing activities take place and then retrieved again on the target website. For example, we can track whether the ads we have placed on other websites have been successful.
  • Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of „profiles with user-related information“, or „profiles“ for short, includes any type of automated processing of personal data that consists of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors‘ behavior or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: „Remarketing“ or „retargeting“ is when, for example, for advertising purposes, a note is made of 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.
  • Controller: a „controller“ is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: „Processing“ means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
  • Targeting: Targeting (or „custom audiences“) is when target groups are determined for advertising purposes, e.g., display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be inferred that this user is interested in advertisements for similar products or the online store where he viewed the products. In turn, we speak of „lookalike audiences“ (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.

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