Introduction
With the following privacy policy we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for which purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Controller
Cozzolino Antonio Sebastian – PRINEN
Zeisigweg 34
71111 – Waldenbuch
Germany
Email address: [email protected]
Phone: +49 (0) 157 7367 8007
Imprint: https://prinen.de/kontakt/
Contact data protection officer
Cozzolino Antonio Sebastian – PRINEN
Zeisigweg 34
71111 – Waldenbuch
Germany
Overview of processing
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Inventory data (e.g. names, addresses).
Content data (e.g. entries in online forms).
Contact data (e.g. email, telephone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. websites visited, interest in content, access times).
Location data (information on the geographical position of a device or person).
Contract data (e.g. subject matter of contract, term, customer category).
Payment data (e.g. bank details, invoices, payment history).
Categories of data subjects
Business and contractual partners.
Interested parties.
Communication partners.
Customers.
Users (e.g. website visitors, users of online services).
Purposes of processing
Assessment of creditworthiness.
Provision of our online offer and user-friendliness.
Visit action evaluation.
Office and organisational procedures.
Cross-device tracking (cross-device processing of user data for marketing purposes).
Direct marketing (e.g. by email or postal).
Interest-based and behavioural marketing.
Contact requests and communication.
Conversion measurement (measurement of the effectiveness of marketing measures).
Profiling (creation of user profiles).
Remarketing.
Reach measurement (e.g. access statistics, recognition of returning visitors).
Security measures.
Tracking (e.g. interest/behavioural profiling, use of cookies).
Provision of contractual services and customer service.
Management and response to enquiries.
Audience building (determination of target groups relevant for marketing purposes or other output of content).
Automated decisions in individual cases
Credit report (decision based on a credit check).
Relevant legal bases
Below we inform you of the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence or domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.
Consent (Art. 6(1)(a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation (Art. 6(1)(c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. We also take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection by design and by default.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.
Transfer and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Within the framework of the so-called “Trans-Atlantic Data Privacy Framework” (TADPF), the EU Commission has also recognised the level of data protection for certain companies from the USA. You can find the list of certified companies as well as further information on the TADPF on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). Information in German and other languages can be found on the website of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en We also inform you about the companies we use that are certified under the Trans-Atlantic Data Privacy Framework.
Use of cookies
Cookies are small text files or other storage markers that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used in an online offer. Cookies can also be used for various purposes, e.g. for the functionality, security and convenience of online offers as well as for the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except where this is not required by law. Consent is not necessary, in particular, if the storage and reading of the information, i.e. also of cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offer). The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Notes on data protection legal bases: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the economic operation of our online offer and improvement of its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which cookies are processed in the course of this privacy policy or as part of our consent and processing 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 his or her 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 stored or preferred content can be displayed directly when the user visits a website again. Likewise, the data of users collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General notes on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can first declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure, within the framework of which the consents of users to the use of cookies, or to the processing and providers named in the cookie consent management procedure, are obtained and can be managed and revoked by users. In this context, the declaration of consent is stored in order not to have to repeat its request and to be able to prove the consent in accordance with the legal obligation. The storage can take place server-side and/or in a cookie (so-called opt-in cookie or by means of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.
Cookie settings/objection option: You can change or withdraw your cookie settings at any time via the cookie banner on our website.
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as associated measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. We only pass on the data of the contractual partners to third parties within the scope of the applicable law insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal reasons of archiving (e.g. for tax purposes generally 10 years). Data disclosed to us by the contractual partner in the course of an order is deleted in accordance with the specifications of the order, in principle after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.
If customers have cancelled their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the customers’ responsibility to back up their data upon cancellation of the customer account.
Economic analyses and market research: For business management reasons and in order to be able to recognise market trends and the wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users including their information, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised values. Furthermore, we take the privacy of users into account and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarised data).
Shop and e-commerce: We process the data of our customers to enable them to select, purchase or order the chosen products, goods and associated services as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, shipping and logistics companies, to carry out the delivery or execution towards 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 order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.
Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. email, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Interested parties, business and contractual partners, customers.
Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organisational procedures, management and response to enquiries, security measures, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles).
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Payment service providers
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, in addition to banks and credit institutions, use other payment service providers (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data such as the name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as the contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means we do not receive any account- or credit-card-related information, but only information confirming or denying the 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 notices of the payment service providers.
The terms and conditions and the data protection notices of the respective payment service providers apply to payment transactions and can be accessed within the respective websites or transaction applications. We refer to these as well for further information and for asserting revocation, information and other data subject rights.
Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Customers, interested parties.
Purposes of processing: Provision of contractual services and customer service.
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Services and service providers used:
PayPal: Payment services and solutions (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; Website: https://www.paypal.com/de; Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the context of the provision of the hosting offer may include all information concerning the users of our online offer that arises in the context of use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or on websites.
Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information concerning the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. We ask you to note that emails on the internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the emails between the sender and the receipt on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability.
Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Contact
When contacting us (e.g. via contact form, email, telephone or via social media), the details of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.
The answering of contact enquiries in the context of contractual or pre-contractual relationships takes place to fulfil our contractual obligations or to answer (pre-)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries.
Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Communication partners, interested parties.
Purposes of processing: Contact requests and communication, management and response to enquiries.
Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Services and service providers used:
Contact form: When users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to handle the communicated concern. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in the answering of the concerns and our statutory retention obligations.
Help Scout: Management of contact requests and communication; Service provider: Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Privacy policy: https://www.helpscout.net/company/legal/privacy/; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): https://www.helpscout.com/company/legal/dpa/; Data processing agreement: https://www.helpscout.com/company/legal/dpa/.
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the newsletter are specifically described within the scope of a newsletter registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.
To register for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personal address in the newsletter, or further details if these are necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with foreign email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list (so-called “blacklist”).
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of emails, this takes place on the basis of our legitimate interests in an efficient and secure dispatch system.
Notes on legal bases: The dispatch of the newsletter takes place on the basis of the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, insofar and as long as this is legally permitted, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider with the dispatch of emails, this takes place on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was conducted in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Analysis and success measurement: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is first collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes the determination of whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us rather to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the success measurement take place, subject to the express consent of the users, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system which serves both our business interests and the expectations of the users.
A separate revocation of the success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to.
Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
Data subjects: Communication partners.
Purposes of processing: Direct marketing (e.g. by email or postal).
Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Objection option (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably email.
Services and service providers used:
CleverReach: Email marketing platform; Service provider: CleverReach GmbH & Co. KG, //CRASH Building, Schafjückenweg 2, 26180 Rastede, Germany; Website: https://www.cleverreach.com/de; Privacy policy: https://www.cleverreach.com/de/datenschutz/; Data processing agreement: Concluded with provider.
Mailchimp: Email dispatch and email marketing platform; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Privacy policy: https://mailchimp.com/legal/; Data processing agreement: https://mailchimp.com/legal/; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): Inclusion in the data processing agreement; Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Web analysis, monitoring and optimisation
Web analysis (also referred to as “reach measurement”) serves the evaluation of the visitor flows of our online offer and may include behaviour, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offer or its functions or content are used most frequently or invite reuse. Likewise, we can understand which areas require optimisation.
In addition to web analysis, we can also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also collected. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimisation, no clear data of users (such as email addresses or names) is stored, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, the data of the users is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioural profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
Security measures: IP masking (pseudonymisation of the IP address).
Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Services and service providers used:
etracker: Web analysis/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1, 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https://www.etracker.com/datenschutz/; Data processing agreement: https://www.etracker.com/av-vertrag/.
Google Analytics: We use Google Analytics to measure and analyse the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It serves to assign analysis information to an end device in order to recognise which content users have accessed within one or more usage processes, which search terms they have used, accessed them again or interacted with our online offer. Likewise, the time of use and its duration are stored, as well as the sources of the users that refer to our online offer and technical aspects of their end devices and browsers. In doing so, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies can be used. In Analytics, data on the geographical location is provided at a higher level by capturing the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. The IP address of the users is not logged and is shortened by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Consent (Art. 6(1)(a) GDPR); Website: https://marketingplatform.google.com/intl/en/about/analytics/; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): https://business.safety.google/adsprocessorterms.
Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (reference is made to further information in this privacy policy). The Tag Manager itself (which implements the tags) does not, for example, create any profiles of users or store cookies. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): https://business.safety.google/adsprocessorterms; Further information: https://privacy.google.com/businesses/adsservices (types of processing as well as the data processed).
Matomo (without cookies): Matomo is a data-protection-friendly web analysis software that is used without cookies and in which the recognition of returning users takes place with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint”, user movements within our online offer are recorded with the help of pseudonymised IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The data of users collected in the course of the use of Matomo is only processed by us and not shared with third parties; Website: https://matomo.org/.
Matomo: Matomo is software used for the purposes of web analysis and reach measurement. In the course of the use of Matomo, cookies are created and stored on the end device of the users. The data of users collected in the course of the use of Matomo is only processed by us and not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Deletion of data: The cookies have a storage duration of a maximum of 13 months.
Online marketing
We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of the users are also collected. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, in the context of online marketing procedures, no clear data of users (such as email addresses or names) is stored, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is generally stored in the cookies or by means of similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analysed for the purposes of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing procedures we use and the network links the profiles of the users with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by consent in the course of registration.
We generally only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. e.g. to the conclusion of a contract with us. The conversion measurement is used solely for the analysis of the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, the data of the users is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person).
Data subjects: Users (e.g. website visitors, users of online services), interested parties.
Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), audience building (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
Security measures: IP masking (pseudonymisation of the IP address).
Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
Objection option (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered summarised for respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.
Services and service providers used:
Facebook Pixel and audience building (Custom Audiences): With the help of the Facebook Pixel (or comparable functions for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook to determine the visitors of our online offer as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook Pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of the users and do not appear annoying. With the help of the Facebook Pixel, we can also track the effectiveness of the Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): The “Facebook EU data transfer addendum” (https://www.facebook.com/legal/EU_data_transfer_addendum) applies in the case of processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the “Platform Terms of Facebook” (https://developers.facebook.com/terms).
Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place advertisements in the Google advertising network (e.g. in search results, in videos, on websites, etc.). The Google Marketing Platform is characterised by the fact that advertisements are displayed in real time based on the presumed interests of users. This allows us to display advertisements for and within our online offer in a more targeted manner in order to present users only with advertisements that potentially correspond to their interests. If, for example, a user is shown advertisements for products in which they were interested on other online offers, this is referred to as “remarketing”; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms; insofar as Google acts as processor, data processing terms for Google advertising products and standard contractual clauses for third-country transfers of data: https://business.safety.google/adsprocessorterms.
Google Ads and conversion measurement: We use the online marketing procedure “Google Ads” to place advertisements in the Google 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 advertisements (so-called “conversion”). Furthermore, we measure the conversion of the advertisements. However, we only learn the anonymous total number of users who have clicked on our advertisement and were redirected to a page provided with a so-called “conversion tracking tag”. We ourselves do not receive any information with which users can be identified; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Further information: Types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information on the services data processing terms between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
Presence in social networks (social media)
We maintain online presences within social networks and process the data of users in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that data of users may be processed outside the area of the European Union. This may result in risks for the users because, for example, the enforcement of the rights of users could be made more difficult.
Furthermore, the data of users within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created on the basis of the usage behaviour and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the computers of the users, in which the usage behaviour and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the objection options (opt-out), we refer to the privacy policies and information of the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you nevertheless need help, you can contact us.
Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).
Services and service providers used:
Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content that users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, for page operators so that they can obtain insights into how people interact with their pages and with the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum.
LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Standard contractual clauses (guaranteeing level of data protection in case of processing in third countries): https://legal.linkedin.com/dpa; Objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Data processing agreement: https://legal.linkedin.com/dpa.
Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA; Website: https://www.pinterest.com; Privacy policy: https://about.pinterest.com/en/privacy-policy; Further information: Pinterest data sharing addendum (ANNEX A): https://business.pinterest.com/en/pinterest-advertising-services-agreement/.
TikTok: Social network / video platform; Service provider: musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA; Website: https://www.tiktok.com; Privacy policy: https://www.tiktok.com/en/privacy-policy.
Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy; Objection option (opt-out): https://adssettings.google.com/authenticated.
Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/en/privacy-policy.
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as “content”).
The integration always presupposes that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavour to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time and further information on the use of our online offer, as well as be linked to such information from other sources.
Notes on legal bases: Insofar as we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, the data of the users is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers).
Data subjects: Users (e.g. website visitors, users of online services), communication partners.
Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, management and response to enquiries.
Legal bases: Legitimate interests (Art. 6(1)(f) GDPR), consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual enquiries (Art. 6(1)(b) GDPR).
Services and service providers used:
Facebook plugins and content: Facebook Social Plugins and content – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer 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 in the course of a transmission (but not the further processing) of “event data” that Facebook collects by means of the Facebook Social Plugins (and embedding functions for content) that are executed on our online offer, or receives in the course of a transmission for the following purposes, jointly responsible: a) display of content as well as 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 the ad delivery and personalisation of functions and content (e.g. improvement of 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 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 fulfil the data subject rights (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous for us), then this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement (“Data Processing Terms”, https://www.facebook.com/legal/terms/dataprocessing), the “Data Security Terms” (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses (“Facebook-EU Data Transfer Addendum”, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy.
Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users is used solely for the purpose of displaying the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (generally carried out within the framework of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertising: https://adssettings.google.com/authenticated.
reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognise whether entries (e.g. in online forms) are made by humans and not by automatically operating machines (so-called “bots”). The processed data may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with reCAPTCHA on other websites, possibly cookies as well as results of manual recognition processes (e.g. answering questions asked or selecting objects in images); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertising: https://adssettings.google.com/authenticated.
Twitter plugins and content: Twitter plugins and buttons – This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Twitter; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/en; Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Objection option (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the display of advertising: https://adssettings.google.com/authenticated.
Vimeo: Video content; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street, New York, New York 10011, USA; Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Objection option (opt-out): We point out that Vimeo can use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=en) or the settings of Google for data use for marketing purposes (https://adssettings.google.com/).
Deletion of data
The data processed by us is deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions lapse (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).
If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided within the scope of the individual data protection notices of this privacy policy.
Amendment and update of the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.
Rights of data subjects
As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
Right of revocation for consents: You have the right to revoke consents granted at any time.
Right of access: You have the right to obtain confirmation as to whether or not data concerning you is being processed and to obtain access to this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to request that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, to request a restriction of the processing of the data.
Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request its transfer to another controller.
Complaint to supervisory authority: You also have the right, in accordance with the legal requirements, 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 concerning you infringes the GDPR.
Definitions of terms
In this section, you will receive an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all to serve understanding. The terms are sorted alphabetically.
Visit action evaluation: “Visit action evaluation” (“conversion tracking”) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is generally stored on the devices of the users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful.
Credit report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). Such automated decisions are only permissible under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract or if national laws permit these decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which behavioural and interest information of users is recorded across devices in so-called profiles by assigning an online identifier to the users. This allows user information to be analysed for marketing purposes regardless of the browsers or devices used (e.g. mobile phones or desktop computers). With most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer serve for the unique identification of a person. IP masking is therefore a means of pseudonymising processing procedures, especially in online marketing.
Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is spoken of when the potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their prior behaviour (e.g. visiting certain websites and staying on them, purchasing behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is generally stored on the devices of the users within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful.
Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to analyse or evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behaviour, social interactions with other people) or to predict them (e.g. the interests in certain content or products, the click behaviour on a website or the location). Cookies and web beacons are frequently used for profiling purposes.
Reach measurement: Reach measurement (also referred to as web analytics) serves the evaluation of the visitor flows of an online offer and may include the behaviour or interests of visitors in certain information, such as content of websites. With the help of reach analysis, website owners can, for example, recognise at what time visitors visit their website and which content they are interested in. This allows them, for example, to adapt the content of the website better to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
Remarketing: “Remarketing” or “retargeting” is spoken of when, for example, for advertising purposes it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
Location data: Location data arises when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serves to indicate at which geographically determinable position of the earth the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
Tracking: “Tracking” is spoken of when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can subsequently be used, for example, to display advertisements to users that presumably correspond to their interests.
Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processing: “Processing” is any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, whether it is the collection, evaluation, storage, transmission or deletion.
Audience building: Audience building (or “custom audiences”) is spoken of when target groups are determined for advertising purposes, e.g. the display of advertisements. Thus, for example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which they viewed the products. “Lookalike audiences” (or similar target groups) is spoken of when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purposes of creating custom audiences and lookalike audiences, cookies and web beacons are generally used.
Mind. 2 Zeichen tippen & los geht’s.
