Privacy Policy
Privacy Policy
Status: March 21, 2026
Table of Contents
- Controller
- Overview of Processing Activities
- Relevant Legal Bases
- Security Measures
- Transfer of Personal Data
- International Data Transfers
- General Information on Data Storage and Deletion
- Rights of Data Subjects
- Business Services
- Payment Procedures
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Registration, Login, and User Account
- Community Functions
- Single Sign-On Login
- Contact and Inquiry Management
- Newsletter and Electronic Notifications
- Sweepstakes and Contests
- Web Analysis, Monitoring, and Optimization
- Online Marketing
- Affiliate Programs and Affiliate Links
- Offering an Affiliate Program
- Presences in Social Networks (Social Media)
- Plug-ins and Embedded Functions and Content
- Changes and Updates
- Definitions
Controller
Glücksmaler Michael Frahm
Schlossstr. 11
19089 Crivitz
Germany
Authorized representatives: Jana Frahm
Email address: info@galerie-frahm.de
Phone: 038635225225
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
- Inventory data.
- Employee data.
- Payment data.
- Location data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication, and procedural data.
- Event data (Facebook).
- Log data.
Categories of data subjects
- Recipients of services and clients.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Sweepstake and contest participants.
- Business and contractual partners.
- Third parties.
- Whistleblowers.
Purposes of processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Conversion measurement.
- Target group formation.
- Affiliate tracking.
- Organizational and administrative procedures.
- Conducting sweepstakes and contests.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Registration procedures.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations and information purposes.
- Whistleblower protection.
- Public relations.
- Business processes and business management procedures.
Relevant Legal Bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you about them in the privacy policy.
- Consent (Art. 6 para. 1 s. 1 lit. a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 s. 1 lit. b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 s. 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 s. 1 lit. f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer as well as automated individual decision-making, including profiling. Furthermore, the data protection laws of the individual federal states may apply.
Security Measures
In accordance with legal requirements and taking into account the state of the art, the costs of implementation, 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 organizational measures to ensure a level of security appropriate to the risk.
These measures particularly include ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.
Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt information transferred between the website or app and the user's browser (or between two servers), thereby protecting data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transfers comply with the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and encrypted.
Transfer of Personal Data
In the course of our processing of personal data, it may occur that this data is transferred to other entities, companies, legally independent organizational units or persons, or is disclosed to them. Recipients of this data may include, for example, service providers entrusted with IT tasks, or providers of services and content embedded in a website. In such cases, we comply with legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
International Data Transfers
Data processing in third countries: If we transfer data to a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing/transferring data to other persons, entities, or companies (which can be identified by the postal address of the respective provider or if the privacy policy explicitly refers to data transfer to third countries), this is always done in accordance with legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which has been recognized as a secure legal framework by an adequacy decision of the EU Commission dated July 10, 2023. Additionally, we have concluded standard contractual clauses with the respective providers, which comply with the requirements of the EU Commission and establish contractual obligations for the protection of your data.
This dual safeguard ensures comprehensive protection of your data: the DPF forms the primary layer of protection, while the standard contractual clauses serve as additional security. Should changes occur within the DPF, the standard contractual clauses will serve as a reliable fallback option. This ensures that your data remains adequately protected at all times, even in the event of any political or legal changes.
For individual service providers, we will inform you whether they are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the U.S. Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
For data transfers to other third countries, corresponding security measures apply, in particular standard contractual clauses, explicit consents, or legally required transfers. Information on third-country transfers and applicable 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.
General Information on Data Storage and Deletion
We delete personal data we process in accordance with legal provisions as soon as the underlying consents are revoked or no further legal bases for processing exist. This applies to cases where the original processing purpose ceases to apply or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer retention or archiving of the data.
In particular, data that must be retained for commercial or tax reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our privacy policy contains additional information on the retention and deletion of data that specifically applies to certain processing activities.
If multiple retention periods or deletion deadlines are specified for data, the longest period is always authoritative. Data that is no longer used for its original purpose but is retained due to legal requirements or other reasons will only be processed for the reasons justifying its retention.
Data retention and deletion: The following general periods apply to retention and archiving under German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, as well as the work instructions and other organizational documents required for their understanding (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
- 8 years - Booking documents, such as invoices and expense receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO and § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g., hourly wage slips, cost accounting sheets, calculation documents, price markings, but also payroll documents, insofar as they are not already booking documents and cash register receipts (§ 147 para. 1 no. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 no. 2 and 3 in conjunction with para. 4 HGB).
- 3 years - Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights, and to process related inquiries, based on previous business experience and common industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Commencement of the period at the end of the year: If a period does not explicitly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships where data is stored, the event triggering the period is the effective date of termination or other cessation of the legal relationship.
Rights of Data Subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, particularly those arising from Articles 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 paragraph 1 letter e or f GDPR, including 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 processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw given consent at any time.
- Right of access: You have the right to request confirmation as to whether personal data concerning you are being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to request the completion of incomplete data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request restriction of processing of the data.
- Right to data portability: You have the right, in accordance with legal requirements, to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to transmit those data to another controller.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Business Services
We process personal data of our contractual and business partners, such as customers, clients, prospective customers, suppliers, and other cooperation partners (collectively "contractual partners"), for the initiation, execution, and processing of contractual relationships and comparable legal relationships. This also includes pre-contractual measures taken upon request, as well as communication in connection with the respective contractual relationship.
The processing serves, in particular, the fulfillment of our primary and secondary contractual obligations. This includes the provision of agreed services, any updating and information obligations, the processing of warranty claims and other service disruptions, the handling of cancellations, terminations of continuous contractual relationships, reversals, refunds, and the processing of other contract-related declarations and inquiries. Both one-time contracts and ongoing contractual relationships are covered.
Specifically, master data such as name, address, and, if applicable, company, contact data such as email address and phone number, contract and service data such as contract subject, contract duration, order or transaction number, usage and performance data, payment and billing data, as well as communication content and histories are processed. If necessary, we also process data that is disclosed or transmitted to us in the context of carrying out an order.
In addition, we process the data to protect our rights and to fulfill legal obligations. This includes, in particular, retention obligations under commercial and tax law, documentation obligations, and, if applicable, proof and accountability obligations. Data processing also takes place on the basis of our legitimate interests in proper business management, internal administration, risk control and IT security, as well as the protection of our business operations and our contractual partners from misuse, endangerment of data, secrets and other legal assets. This may also include the involvement of external service providers such as IT and telecommunications providers, transport and logistics companies, payment service providers, banks, tax and legal advisors or other vicarious agents, insofar as this is necessary for contract execution or to fulfill legal obligations.
Personal data will only be passed on to third parties if this is necessary for the fulfillment of the contract, for the implementation of pre-contractual measures, for the protection of legitimate interests or for the fulfillment of legal obligations. We will inform you separately about further processing, in particular for marketing purposes, within the framework of this data protection declaration.
We will inform the contractual partners about which data is required in individual cases during the data collection, for example in online forms by appropriate marking or in personal contact.
The data will be deleted as soon as it is no longer required for the aforementioned purposes and no legal retention obligations prevent deletion. Legal retention periods, in particular under commercial and tax law, may require longer storage. Data transmitted in the context of a specific order will be deleted after completion of the order and expiry of any retention periods, unless there are further legal or contractual obligations to store it.
The legal basis for the processing is Art. 6 para. 1 lit. b GDPR for the implementation of pre-contractual measures and for the fulfillment of the respective contractual relationship, as well as Art. 6 para. 1 lit. c GDPR for the fulfillment of legal obligations. Insofar as the processing is based on legitimate interests, it is carried out on the basis of Art. 6 para. 1 lit. f GDPR. Insofar as the processing is based on Art. 6 para. 1 lit. f GDPR, it is carried out to protect our legitimate interests in proper and efficient business organization, internal administration and documentation of business processes, the enforcement and defense of legal claims, ensuring IT and data security, preventing misuse and fraud, and the economic management and development of our business operations. These interests consist in particular in ensuring safe and legally compliant business operations and in safeguarding our entrepreneurial freedom of action.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., subject matter of the contract, term, customer category); usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Affected persons: Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; security measures; communication; office and organizational procedures; organizational and administrative procedures. Business processes and business administration procedures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, procedures and services:
- Online shop, order forms, e-commerce and service fulfillment: We process the data of our customers in order to enable them to select, acquire or order the chosen products, goods and associated services, as well as their payment and provision, delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is marked as such in the context of the ordering or comparable acquisition process and includes the information required for delivery, provision and billing, as well as contact information for any queries; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Payment procedures
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer efficient and secure payment options to the data subjects and use other service providers in addition to banks and credit institutions (collectively "payment service providers"). Payment transactions are carried out exclusively via encrypted connections in accordance with the state of the art, so that the data entered is protected from unauthorized access during transmission.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contractual, sum and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or denying payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission serves the purpose of identity and credit checks. We refer to the terms and conditions and the data protection information of the payment service providers for this.
For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed on their respective websites or transaction applications. We also refer to these for further information and for exercising rights of withdrawal, information and other data subject rights.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); 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., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g., IP addresses, time stamps, identification numbers, persons involved). Contact data (e.g., postal and email addresses or telephone numbers).
- Affected persons: Service recipients and clients; business and contractual partners. Interested parties.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Business processes and business administration procedures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, procedures and services:
- Apple Pay: Payment services (technical integration of online payment methods); Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. 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: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy Policy: https://www.klarna.com/de/datenschutz.
- 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: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy Policy: https://www.paypal.com/de/legalhub/paypal/privacy-full.
- Visa: Payment services (technical integration of online payment methods); Service provider: Visa Europe Services Inc., London Branch, 1 Sheldon Square, London W2 6TT, GB; Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offering and web hosting
We process user data to enable them to use our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the users' browser or end device.
- Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g., IP addresses, time stamps, identification numbers, persons involved); log data (e.g., log files concerning logins or data retrieval or access times). Content data (e.g., text or image messages and contributions and related information, such as authorship or time of creation).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; IT infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Provision of online services on rented storage space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web hoster"); Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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". Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volume, 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. Server log files can be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (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; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is necessary for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.
- Email sending and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the email dispatch (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that emails are generally not sent encrypted on the Internet. As a rule, emails are encrypted during transport, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume responsibility for the transmission path of emails between the sender and the receipt on our server; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- STRATO: Services in the field of providing IT infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: STRATO AG, Pascalstraße 10,10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy Policy: https://www.strato.de/datenschutz/. Data Processing Agreement: Provided by the service provider.
- Wix: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://de.wix.com/; Privacy Policy: https://de.wix.com/about/privacy; Data Processing Agreement: https://www.wix.com/about/privacy-dpa-users. Basis for third-country transfers: Data Privacy Framework (DPF).
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (Provided by the service provider).
Use of cookies
The term "cookies" refers to functions that store and retrieve information on users' end devices. Cookies can also be used for various purposes, such as the functionality, security, and convenience of online services, as well as for analyzing visitor flows. We use cookies in accordance with legal regulations. For this purpose, we obtain the users' consent in advance if necessary. If consent is not required, we rely on our legitimate interests. This applies when the storage and retrieval of information is essential to provide explicitly requested content and functions. This includes, for example, storing settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.
Notes on data protection legal bases: Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g., browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a website. The user data collected with the help of cookies can also be used for reach measurement. If we do not explicitly inform users about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that these are permanent and the storage duration can be up to two years.
General notes on revocation and objection (opt-out): Users can revoke their given consents at any time and also declare an objection to the processing in accordance with legal requirements, including via the privacy settings of their browser.
- Types of data processed: Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
- Persons affected: Users (e.g., website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further notes on processing processes, procedures and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent for the use of cookies or for the procedures and providers mentioned in the context of the consent management solution. This procedure serves to obtain, log, manage and revoke consents, particularly with regard to the use of cookies and comparable technologies that are used to store, read out and process information on users' end devices. Within the framework of this procedure, users' consents for the use of cookies and the associated processing of information, including the specific processing operations and providers mentioned in the consent management procedure, are obtained. Users also have the option to manage and revoke their consents. The consent declarations are stored to avoid repeated queries and to be able to provide proof of consent in accordance with legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general notes apply: The storage period for consent is up to two years. A pseudonymous user identifier is created and stored together with the time of consent, details of the scope of consent (e.g., relevant categories of cookies and/or service providers), and information about the browser, system, and end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Registration, Login and User Account
Users can create a user account. During registration, users are informed of the required mandatory information and this is processed for the purpose of providing the user account based on the fulfillment of contractual obligations. The data processed includes, in particular, login information (username, password, and an email address).
When using our registration and login functions and when using the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. This data is generally not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users can be informed by email about processes relevant to their user account, such as technical changes.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or telephone numbers); Content data (e.g., text or image messages and posts and related information, such as authorship details or creation time); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Log data (e.g., log files concerning logins or data retrieval or access times).
- Persons affected: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Organizational and administrative procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section. Deletion upon termination.
- Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures and services:
- Registration with real name: Due to the nature of our community, we ask users to use our service only under their real names. This means that the use of pseudonyms is not permitted; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- User profiles are not public: User profiles are not publicly visible or accessible.
- Setting the visibility of profiles: Users can use settings to determine the extent to which their profiles are visible or accessible to the public or only to specific groups of people; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Two-factor authentication: Two-factor authentication provides an additional layer of security for your user account and ensures that only you can access your account, even if someone else knows your password. For this purpose, in addition to your password, you must perform another authentication measure (e.g., enter a code sent to a mobile device). We will inform you about the procedure we use; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Deletion of data upon termination: If users have terminated their user account, their data relating to the user account will be deleted, subject to legal permission, obligation or the users' consent; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- No retention obligation for data: It is up to the users to secure their data upon termination before the end of the contract. We are entitled to irrevocably delete all user data stored during the contract period; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Community Functions
The community functions we provide allow users to engage in conversations or otherwise interact with each other. Please note that the use of community functions is only permitted in compliance with applicable laws, our terms and policies, and the rights of other users and third parties.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Persons affected: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section.
- Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures and services:
- Storage of data for security purposes: User contributions and other entries are processed for the purposes of community and conversation functions and, subject to legal obligations or legal permission, are not disclosed to third parties. An obligation to disclose may arise, in particular, in the case of illegal contributions for the purpose of legal prosecution. We point out that, in addition to the content of the contributions, their time and the IP address of the users are also stored. This is done to be able to take appropriate measures to protect other users and the community; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Right to delete content and information: The deletion of user contributions, content or information is permissible to the necessary extent after a reasonable consideration, insofar as there are concrete indications that they constitute a violation of legal rules, our guidelines or the rights of third parties; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Restricted deletion of conversation contributions: Out of consideration for other users, the user's conversation contributions remain stored even after termination and account deletion, so that conversations, comments, advice or similar communication between and among users do not lose their meaning or reverse. User names are deleted or pseudonymized, unless they were already pseudonyms. Users can assert the complete deletion of conversation contributions with us at any time; Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
- Protection of own data: Users decide for themselves which data they disclose about themselves within our online offering. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and to publish personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect access data very carefully and use secure passwords (i.e., above all, character combinations that are as long and random as possible); Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Single Sign-On Login
"Single Sign-On" or "Single Sign-On Login or Authentication" refers to procedures that allow users to log in to our online offering using a user account with a Single Sign-On provider (e.g., a social network). The prerequisite for Single Sign-On authentication is that users are registered with the respective Single Sign-On provider and enter the required access data in the designated online form, or are already logged in with the Single Sign-On provider and confirm the Single Sign-On login via a button.
Authentication takes place directly with the respective Single Sign-On provider. As part of such an authentication, we receive a user ID with the information that the user is logged in with this user ID at the respective Single Sign-On provider and an ID (so-called "User Handle") that cannot be used by us for other purposes. Whether additional data is transmitted to us depends solely on the Single Sign-On procedure used, the data releases selected during authentication, and also on what data users have released in the privacy or other settings of the user account with the Single Sign-On provider. Depending on the Single Sign-On provider and the users' choice, various data may be involved, usually the email address and username. The password entered with the Single Sign-On provider as part of the Single Sign-On procedure is neither visible to us nor stored by us.
Users are asked to note that their data stored with us may be automatically compared with their user account with the Single Sign-On provider, but this is not always possible or actually happens. If, for example, users' email addresses change, they must manually change them in their user account with us.
We may use Single Sign-On login, if agreed with the users, as part of or before the fulfillment of the contract, insofar as users have been asked to do so, process it with consent, and otherwise use it based on our legitimate interests and the interests of users in an effective and secure login system.
Should users decide to no longer use the link between their user account with the Single Sign-On provider for the Single Sign-On procedure, they must remove this connection within their user account with the Single Sign-On provider. If users wish to delete their data with us, they must terminate their registration with us.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons). Event data (Facebook) ("Event data" is information sent to the Meta provider, for example, via Meta Pixel (either via apps or other channels), and relates to individuals or their actions. This data includes details about website visits, interactions with content and functions, app installations, and product purchases. The processing of event data aims to create target audiences for content and advertisements (Custom Audiences). It is important to note that event data does not include actual content such as comments written, login information, or contact information such as names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target audiences formed from it disappear when our Meta user accounts are deleted.).
- Persons affected: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations; Security measures; Login procedures. Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section. Deletion upon termination.
- Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing processes, procedures and services:
- Apple Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.apple.com/de/. Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
- Facebook Single Sign-On: Authentication service of the Facebook platform; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/; Data Processing Agreement: https://www.facebook.com/legal/terms/dataprocessing. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Google Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.de; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Opt-out option: Settings for the display of advertisements: https://myadcenter.google.com/.
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Instagram Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations. - Together with Meta Platforms Ireland Limited, we are jointly responsible for the collection or receipt, within the scope of a transmission (but not the further processing), of "Event Data" that Facebook collects via the Instagram Single Sign-On login procedures executed on our online offering, or receives within the scope of a transmission, for the following purposes: a) Display of content and advertising information corresponding to the presumed interests of users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improvement of ad delivery and personalization of functions and content (e.g., improving the detection of what content or advertising information presumably corresponds to users' interests). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, address information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., contain no information about individual users and are anonymous to us), this processing does not take place within the scope of joint responsibility, 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 information, deletion, objection, and complaint to 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 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy Policy: https://privacycenter.instagram.com/policy/. - Microsoft Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/security/business/identity-access/azure-active-directory-single-sign-on; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Basis for third-country transfers: Data Privacy Framework (DPF). Further information: https://www.microsoft.com/de-de/trust-center.
- OneLogin Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: OneLogin Inc., 848 Battery Street, San Francisco, CA 94111, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.onelogin.com/de; Privacy Policy: https://www.oneidentity.com/legal/privacy.aspx. Basis for third-country transfers: Data Privacy Framework (DPF).
- OpenID Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: OpenID Foundation, 2400 Camino Ramon, Suite 375, San Ramon, CA 94583, USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://openid.net; Privacy Policy: https://openid.net/policies/. Basis for third-country transfers: Data Privacy Framework (DPF).
- X Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: X Internet Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://x.com; Privacy Policy: https://x.com/privacy, (Settings: https://x.com/personalization); Data Processing Agreement: https://privacy.x.com/en/for-our-partners/global-dpa. Basis for third-country transfers: Standard Contractual Clauses (https://privacy.x.com/en/for-our-partners/global-dpa).
- Yahoo! Single Sign-On: Authentication services for user logins, provision of single sign-on functions, management of identity information and application integrations; Service provider: Oath (EMEA) Limited, 5-7 Point Square, North Wall Quay, Dublin 1, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://developer.yahoo.com/sign-in-with-yahoo/. Privacy Policy: https://legal.yahoo.com/ie/de/yahoo/privacy/index.html.
Contact and Enquiry Management
When contacting us (e.g., by post, contact form, email, phone, or via social media) and within the scope of existing user and business relationships, the data of the inquiring persons will be processed as far as this is necessary to answer the contact inquiries and any requested measures.
- Types of data processed: Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or visual messages and posts and related information, such as authorship or time of creation). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
- Data subjects: Communication partners.
- Purposes of processing and legitimate interests: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online form). Provision of our online offering and user-friendliness.
- Retention and deletion: Deletion according to the information in the section "General information on data storage and deletion".
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
- Contact form: When contacting us via our contact form, by email or other communication channels, we process the personal data transmitted to us to answer and handle the respective request. This usually includes details such as name, contact information and, if applicable, further information communicated to us and necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal bases: Performance of contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") exclusively with the consent of the recipients or on a legal basis. If the content of a newsletter is described during registration, this content is decisive for the users' consent. For subscribing to our newsletter, providing your email address is usually sufficient. However, to offer you a personalized service, we may ask for your name for personal address in the newsletter or for further information if it is necessary for the purpose of the newsletter.
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 prove a previously given consent. The processing of this data will be limited to the purpose of potential defense against claims. An individual deletion request is possible at any time, provided that the previous existence of consent is simultaneously confirmed. In the case of obligations for permanent observance of objections, we reserve the right to store the email address solely for this purpose in a blocking list (so-called "blocklist").
The registration process is logged based on our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Content:Information about us, our services, promotions and offers.
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers). Metadata, communication data, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
- Data subjects: Communication partners. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Direct marketing (e.g., by email or post). Provision of contractual services and fulfillment of contractual obligations.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Right 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. A link to cancel the newsletter can be found either at the end of each newsletter or you can use one of the contact options provided above, preferably email, for this purpose.
Further information on processing processes, procedures and services:
- Prerequisite for the use of free services: Consent to the sending of mailings may be made a prerequisite for the use of free services (e.g., access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
Sweepstakes and Contests
We process personal data of participants in sweepstakes and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution, and settlement of the sweepstake, the participants have consented to the processing, or the processing serves our legitimate interests (e.g., in the security of the sweepstake or the protection of our interests against misuse by possible collection of IP addresses when submitting sweepstake entries).
If participants' contributions are published within the scope of the sweepstakes (e.g., as part of a vote or presentation of the sweepstake entries or the winners, or reporting on the sweepstake), we point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the sweepstake 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 data protection regulations of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by the participants within the scope of the sweepstake, and inquiries regarding the sweepstake should be directed to us.
The participants' data will be deleted as soon as the sweepstake or contest has ended and the data is no longer required to inform the winners or because no further inquiries about the sweepstake are to be expected. In principle, the participants' data will be deleted no later than 6 months after the end of the sweepstake. Winner data may be retained longer to, for example, answer questions about prizes or fulfill prize services; in this case, the retention period depends on the type of prize and is, for example, up to three years for goods or services to process warranty cases. Furthermore, participants' data may be stored longer, e.g., in the form of reporting on the sweepstake in online and offline media.
If data was also collected for other purposes within the scope of the sweepstake, its processing and retention period are governed by the data protection notices for this use (e.g., in the case of a newsletter subscription as part of a sweepstake).
- Types of data processed: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., textual or visual messages and posts and related information, such as authorship or time of creation).
- Data subjects: Sweepstakes and contest participants.
- Purposes of processing and legitimate interests: Conducting sweepstakes and contests.
Web Analytics, Monitoring, and Optimization
Web analytics (also referred to as "reach measurement") is used to evaluate the visitor flows of 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 offering or its functions or content are most frequently used, or invite reuse. We can also understand which areas need optimization.
In addition to web analytics, we may also use testing procedures to test and optimize different versions of our online offering or its components.
Unless otherwise specified below, profiles, i.e. data compiled for a usage process, may be created for these purposes and information stored in a browser or on an end device and then read out. The data collected includes, in particular, visited websites and elements used there, as well as technical information, such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data by us or by the providers of the services we use, the processing of location data is also possible.
In addition, users' IP addresses are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as e-mail addresses or names) are stored within the framework of web analytics, A/B testing and optimization, 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 purpose of the respective procedures.
Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Profiles with user-related information (creation of user profiles). Provision of our online offering and user-friendliness.
- Retention and Deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section. Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security Measures: IP masking (pseudonymization of the IP address).
- Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
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Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain unique data such as names or email addresses. It serves to assign analytical information to an end device to recognize which content users have viewed within one or different usage processes, which search terms they have used, re-accessed, or interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of different 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, IP address data is used exclusively for this derivation of geolocation data before being immediately deleted. They are not logged, are not accessible, and are not used for further purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before traffic is forwarded to Analytics servers for processing; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security Measures: IP masking (pseudonymization 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), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Objection Option (Opt-Out): Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for ad display: https://myadcenter.google.com/personalizationoff. Further Information: https://business.safety.google/adsservices/ (types of processing and processed data).
Online Marketing
We process personal data for the purpose 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 their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called "cookie") or similar procedures are used, by means of which the information relevant to the user for the display of the aforementioned content is stored. This may include, for example, viewed content, visited websites, 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 used functions. If users have consented to the collection of their location data, these can also be processed.
In addition, users' IP addresses are stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) are stored in the context of online marketing procedures, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual user identity, but only the information stored in their profiles.
The statements in the profiles are generally stored in cookies or by similar procedures. These cookies can generally also be read out later on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily when users are, for example, members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, for example, by consenting during registration.
In principle, we only have access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. for example, to a contract with us. Conversion measurement is used solely for the success analysis of our marketing measures.
Unless otherwise stated, please assume that cookies used are stored for a period of two years.
Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic, and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
Notes on Revocation and Objection:
We refer to the privacy policies of the respective providers and the objection options (so-called "opt-out") specified for the providers. If no explicit opt-out option has been provided, there is the possibility that you can disable cookies in your browser settings. However, this may restrict the functionality of our online offering. We therefore also recommend the following opt-out options, which are offered in a summarized manner for the respective areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://youradchoices.ca/.
c) USA: https://optout.aboutads.info/.
d) Cross-region: https://optout.aboutads.info.
- Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and process data (e.g., IP addresses, time specifications, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Reach measurement (e.g., access statistics, recognition of returning visitors); Tracking (e.g., interest/behavior-based profiling, use of cookies); Audience targeting; Marketing; Profiles with user-related information (creation of user profiles). Conversion measurement (measurement of the effectiveness of marketing measures).
- Retention and Deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section. Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods may be stored on users' devices for a period of two years).
- Security Measures: IP masking (pseudonymization of the IP address).
- Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing procedures, methods, and services:
- Google Ads and Conversion Measurement: Online marketing procedure for the purpose of placing content and advertisements within the service provider's advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e., whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversions). 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 Basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. 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 processed data: https://business.safety.google/adsservices/. Data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
- Google AdSense with Personalized Ads: We integrate the Google AdSense service, which allows personalized ads to be placed within our online offering. Google AdSense analyzes user behavior and uses this data to display targeted advertising that is tailored to the interests of our visitors. We receive financial compensation for each ad placement or other types of use of these ads; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 processed data: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
- Google AdSense with Non-Personalized Ads: We use the Google AdSense service to display non-personalized ads in our online offering. These ads are not based on individual user behavior but are selected based on general characteristics such as the content of the page or your approximate geographical location. We receive compensation for the display or other use of these ads; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6 para. 1 sentence 1 lit. 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 processed data: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Affiliate Programs and Affiliate Links
In our online offering, we include so-called affiliate links or other references (which may include search masks, widgets, or discount codes) to the offers and services of third-party providers (collectively referred to as "affiliate links"). If users follow the affiliate links or subsequently take advantage of the offers, we may receive a commission or other benefits from these third-party providers (collectively referred to as "commission").
To track whether users have taken advantage of the offers of an affiliate link we use, it is necessary for the respective third-party providers to know that users have followed an affiliate link embedded within our online offering. The assignment of affiliate links to the respective transactions or other actions (e.g., purchases) serves solely the purpose of commission billing and is cancelled as soon as it is no longer required for this purpose.
For the purposes of the aforementioned assignment of affiliate links, the affiliate links can be supplemented with certain values that are part of the link or can otherwise be stored, e.g., in a cookie. Such values may include, in particular, the referring website (referrer), the time, an online identifier of the website operators on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer, and an online identifier of the user.
Notes on Legal Bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient, economical, and user-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: Contract data (e.g., subject matter of contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
- Data subjects: Interested parties. Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Affiliate tracking.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Offering an Affiliate Program
We offer an affiliate program, i.e., commissions or other benefits (collectively referred to as "commission") for users (referred to as "affiliates") who refer to our offers and services. The referral is made via a link assigned to the respective affiliate or other methods (e.g., discount codes) that allow us to recognize that the use of our services was based on the referral (collectively referred to as "affiliate links").
In order to track whether users utilize our services based on the referrals provided by the affiliates
- Types of data processed: Contract data (e.g., subject matter of contract, term, customer category); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with). Log data (e.g., log files regarding logins or data retrieval).
- Data subjects: Users (e.g., website visitors, users of). Business and contract partners.
- Purposes of processing and legitimate interests: Provision of contractual services and fulfillment of contractual obligations. Affiliate tracking.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Presences in social networks (Social Media)
We maintain online presences within social networks and process user data in this context to communicate with active users there or to offer information about ourselves.
We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on the users' computers, in which the user behavior and the interests of the users are stored. In addition, data independent of the devices used by the users can also be stored in the user profiles (especially if they are members of the respective platforms and logged in there).
For a detailed description of the respective forms of processing and the objection options (opt-out), we refer to the privacy policies and information of the operators of the respective networks.
Even in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. Should you still need assistance, you can contact us.
- Types of data processed: Contact data (e.g., postal and e-mail addresses or telephone numbers); Content data (e.g., textual or visual messages and posts and related information, such as authorship or creation time); Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Inventory data (e.g., full name, residential address, contact information, customer number, etc.). Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Communication; Feedback (e.g., collecting feedback via online form); Public relations; Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)). Public relations and information purposes.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
- Bluesky: Decentralized social media network - enables creating, sharing, and commenting on content as well as following user profiles; Service provider: Bluesky, PBLLC., Seattle, USA, support@bsky.app; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://bsky.social/. Privacy Policy: https://bsky.social/about/support/privacy-policy.
- Instagram: Social network, enables sharing photos and videos, commenting on and liking posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://privacycenter.instagram.com/policy/. Basis for Third-Country Transfers: Data Privacy Framework (DPF).
- Facebook Pages: Profiles within the social network Facebook - The controller is jointly with Meta Platforms Ireland Limited responsible for the collection and transmission of data of visitors to our Facebook page ("Fanpage"). This includes in particular information about user behavior (e.g., viewed or interacted content, actions performed) as well as device information (e.g., IP address, operating system, browser type, language settings, cookie data). More details can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the "Page Insights" service, which provide information on how people interact with our page and its content. This is based on an agreement with Facebook ("Information about Page Insights": https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, among other things, security measures and the exercise of data subject rights. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or deletion directly to Facebook. The rights of users (in particular information, deletion, objection, complaint to a supervisory authority) remain unaffected by this. Joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). For further processing, including a possible transfer to Meta Platforms Inc. in the USA, Meta Platforms Ireland Limited is solely responsible; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/privacy/policy/. Basis for Third-Country Transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
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LinkedIn: Social network - We are jointly with LinkedIn Ireland Unlimited Company responsible for the collection (but not the further processing) of data of visitors used for the creation of "Page Insights" (statistics) of our LinkedIn profiles. This data includes information about the types of content that users view or interact with, as well as the actions they perform. In addition, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information on the processing of user 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", https://legal.linkedin.com/pages-joint-controller-addendum), which, in particular, regulates what security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, address requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is exclusively the responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transmission of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - Pinterest: Social network, enables sharing photos, commenting, liking and curating posts, sending messages, subscribing to profiles; Service provider: Pinterest Europe Limited, 2nd Floor, Palmerston House, Fenian Street, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.pinterest.com. Privacy Policy: https://policy.pinterest.com/de/privacy-policy.
- Snapchat: Social network, enables sharing photos and videos, commenting on and liking posts, sending messages, subscribing to profiles and pages; Service provider: Snap Inc., 3000 31st Street, Santa Monica, California 90405 USA; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.snapchat.com/; Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy. Basis for Third-Country Transfers: Standard Contractual Clauses (https://www.snap.com/en-US/terms/standard-contractual-clauses).
- Threads: Social network; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.threads.com/. Privacy Policy: https://help.instagram.com/515230437301944.
Plug-ins 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"). 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 users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the display of this content or functions. We endeavor to use only such content whose respective providers use the IP address merely 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. "Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the users' device and may contain technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, but can also be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the permission. Otherwise, user data will be processed on the basis of our legitimate interests (i.e., interest in efficient, economic and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Types of data processed: Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta, communication and procedural data (e.g., IP addresses, time stamps, identification numbers, persons involved); Location data (information about the geographical position of a device or a person). Event data (Facebook) ("Event data" are information, which for example, is sent to the provider Meta via Meta pixels (either via apps or other channels) and relates to individuals or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations, and product purchases. The processing of event data is done with the aim of creating target audiences for content and advertising messages (Custom Audiences). It is important to note that event data does not include actual content such as comments written, login information, or contact information such as names, email addresses, or phone numbers. "Event data" is deleted by Meta after a maximum of two years, and the target audiences formed from it disappear with the deletion of our Meta user accounts.).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing and legitimate interests: Provision of our online offering and user-friendliness; reach measurement (e.g., access statistics, recognition of returning visitors); tracking (e.g., interest/behavioral profiling, use of cookies); audience formation. Marketing.
- Retention and deletion: Deletion in accordance with the information in the "General information on data storage and deletion" section. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users' devices for a period of two years.).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Facebook plugins and content: Facebook Social Plugins and content - This may include, for example, content such as images, videos or texts and buttons that allow users to share content from 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 with Meta Platforms Ireland Limited for the collection or receipt of "event data" by Facebook via the Facebook Social Plugins (and content embedding functions) executed on our online offering or in the context 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 personalization 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 ("Addendum for Controllers", https://www.facebook.com/legal/controller_addendum), which specifically regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, address requests for information or deletion directly to Facebook). Note: If Facebook provides us with metrics, analyses and reports (which are aggregated, i.e., do not contain information on individual users and are anonymous to us), this processing does not take place within the framework of joint responsibility, 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 information, deletion, objection and complaint to 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 para. 1 sentence 1 lit. 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 (provision on own server): Provision of font files for user-friendly display of our online offering; Service provider: Google Fonts are hosted on our server, no data is transmitted to Google; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Google Fonts (obtained from Google Server): Obtaining fonts (and icons) for the purpose of technically secure, maintenance-free and efficient use of fonts and icons with regard to topicality and loading times, their uniform presentation and consideration of possible licensing restrictions. The IP address of the user is communicated to the font provider so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA - When visiting our online offering, 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 Google Fonts' Cascading Style Sheets (CSS) and then 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 that describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the website on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. 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 wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. For the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. 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 of the top integrations based on the number of font requests can be generated. According to its own statements, Google does not use any of the information collected by Google Fonts to create profiles of end-users or to display targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 "Google Maps" service provided by Google. The processed data 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 para. 1 sentence 1 lit. a) GDPR); Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy. Basis for third country transfers: Data Privacy Framework (DPF).
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Opt-out option: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://myadcenter.google.com/personalizationoff.
- YouTube videos: Videos stored on YouTube are embedded within our online offering. The integration of these YouTube videos takes place via a special domain using the "youtube-nocookie" component in the so-called "enhanced privacy mode". In "enhanced privacy mode", only information, including your IP address and information about your browser and your end device, can be stored on your end device in cookies or by comparable procedures that YouTube requires for the output, control and optimization of the video display until the video starts. As soon as you play the videos, information for the analysis of user behavior as well as for storage in the user profile and for the personalization of content and advertisements can also be processed by YouTube. The storage period for cookies can be up to two years; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: Data Privacy Framework (DPF). Further information: https://support.google.com/youtube/answer/171780?hl=de-DE#zippy=%2Cturn-on-privacy-enhanced-mode%2Ferweiterten-datenschutzmodus-aktivieren.
Legal bases (Germany): Insofar as we process data to fulfill our legal obligations in accordance with the Whistleblower Protection Act (HinSchG), the legal basis for processing is Article 6 (1) sentence 1 lit. c) GDPR and, in the case of special categories of personal data, Article 9 (2) lit. g) GDPR, Section 22 BDSG, in each case in conjunction with Section 10 HinSchG. This refers to the obligation to establish and operate an internal whistleblower reporting office, the fulfillment of its legal tasks and, in the event of the use of data collected in the reporting procedure, the taking of further
Types of data processed: In the context of receiving and processing reports, as well as in the subsequent whistleblower procedure, we may collect various data. This includes, in particular, data provided by a whistleblower, such as: Name, contact details and location of the person making the report, names and data of possible witnesses or persons affected by the report, names and data of the persons against whom the report is directed, data about the alleged misconduct, further relevant details, provided by the
Special categories of personal data: It may happen that we collect special types of personal data in the course of our activities, especially if these are communicated by a whistleblower. These include: health-related data of a person, data on racial or ethnic origin
Use of our online forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in your browser's "Incognito mode". Here's how to open an Incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.
When you access our website in normal mode, your
Providing names: You have the option to submit reports anonymously. However, unless prohibited by national laws, we recommend providing your name and contact details. This allows us to follow up on the report more effectively and, if necessary, contact you directly.
If you provide your name and contact details, your identity will be kept strictly confidential
Disclosure of data to third parties: Data related to the submitted reports will only be disclosed by us to third parties under certain circumstances. This occurs either a) if you have given us your express consent, or b) if there is a legal obligation to disclose the data. Possible third parties include public authorities, government, regulatory, or tax authorities, if the disclosure is necessary to fulfill a legal or regulatory obligation. Furthermore, within the framework of legal provisions, we may commission lawyers and other expert advisors. These are authorized to examine alleged misconduct and take necessary measures after an investigation, such as initiating disciplinary or legal proceedings. In addition, carefully selected and monitored service providers may receive data from us for these purposes (e.g., operators of a web-based reporting system). However, these service providers are contractually obliged to comply with the applicable data protection regulations within the framework of order processing.
Data retention and deletion: Personal data will only be processed for as long as it is necessary to fulfill the processing purposes described above. If this data is no longer required for the stated purposes, it will be deleted. In certain situations, it may be necessary to
Technical and organizational measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. Incoming reports are handled by specially
Changes and Updates
We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as changes require your cooperation (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that addresses may change over time and we ask you to check the information before contacting them.
Definitions of Terms
In this section, you will find an overview of the terms used in this privacy policy. Insofar as the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.
- Affiliate Tracking: Affiliate tracking involves logging links that refer users from linking websites to websites with product or other offers. The operators of the respective linking websites can receive a commission if users follow these so-called affiliate links and subsequently take advantage of the offers (e.g., buy goods or use services). For this to work, providers need to be able to track whether users who are interested in certain offers then take advantage of them as a result of the affiliate links. Therefore, for the functionality of affiliate links, it is necessary to supplement them with certain values that become part of the link or are otherwise stored, e.g., in a cookie. These values include in particular the originating website (referrer), the time, an online identifier of the operators of the website where the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values, such as ad ID, partner ID, and categorizations.
- Employees: Employees are individuals who are in an employment relationship, whether as staff, salaried employees, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It involves the employer's obligation to pay the employee remuneration, while the employee performs their work. The employment relationship includes various phases, including its establishment, when the employment contract is concluded, its performance, when the employee carries out their work activities, and its termination, when the employment relationship ends, whether by termination, mutual agreement, or otherwise. Employee data includes all information relating to these individuals and relevant to their employment. This encompasses aspects such as personal identification data, identification numbers, salary and bank details, working hours, holiday entitlements, health data, and performance reviews.
- Inventory Data: Inventory data comprises essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar assignments. This data may include personal and demographic details such as names, contact information (addresses, phone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, facilities, or systems, by enabling clear assignment and communication.
- Content Data: Content data includes information generated during the creation, editing, and publication of all types of content. This category of data may include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content itself but also includes metadata that provides information about the content, such as tags, descriptions, author information, and publication dates.
- Contact Data: Contact data is essential information that enables communication with individuals or organizations. It includes, among other things, telephone numbers, postal addresses, and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Conversion Measurement: Conversion measurement (also known as "visit action evaluation") is a procedure used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites where the marketing measures are carried out and then retrieved again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful.
- Meta, Communication, and Process Data: Meta, communication, and process data are categories that contain information about how data is processed, transmitted, and managed. Meta-data, also known as data about data, includes information describing the context, origin, and structure of other data. It can include file size, creation date, author of a document, and revision histories. Communication data captures the exchange of information between users across various channels, such as email traffic, call logs, social media messages, and chat histories, including the involved parties, timestamps, and transmission paths. Process data describes the processes and workflows within systems or organizations, including workflow documentation, transaction and activity logs, and audit trails used to track and review operations.
- Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they stay on certain pages, and through which paths they navigate an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
- 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 form of automated processing of personal data consisting of using that personal data to evaluate 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.) to analyze, evaluate or predict them (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.
- Log Data: Log data is information about events or activities that have been logged in a system or network. This data typically includes information such as timestamps, IP addresses, user actions, error messages, and other details about the usage or operation of a system. Log data is often used to analyze system problems, monitor security, or generate performance reports.
- Reach Measurement: Reach measurement (also known as web analytics) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, operators of online offerings can, for example, identify at what time users visit their websites and what content they are interested in. This allows them, for example, to better adapt the content of the websites to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
- Location Data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, WLAN, or similar technical means and functions for location determination. Location data serves to indicate the geographically determinable position on Earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
Created with the free privacy policy generator Datenschutz-Generator.de by Dr. Thomas Schwenke
