Disclaimer: The sample below has been prepared by a lawyer (Dr. jur. Schwenke, LL.M. commercial (UoA), Certified Data Protection Auditor (DSA-TÜV) Certified Data Protection Officer (TÜV Süd)) has been created according to the typical requirements of an online store. However, you should use the template only after careful review and adaptation to your specific business model. The following sample therefore contains additional notes that you must observe and red passages that you must particularly check and adjust if necessary. Please remove the notes after editing. If in doubt, seek legal advice. Copyright: You may use the design within the domain/website as long as it is also covered by your Marketpress license. Passing on to third parties, including customers (e.g. as developers) is not permitted.

Privacy policy

Introduction

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

The terms used are not gender specific.

Status: XX.XX.20XX

Please indicate the status of the privacy policy.

Responsible

First name, last name / Company
Street, house no.
Zip code, city
Country

E-mail address: Your email address

Phone: Your phone number (optional)

Imprint: URL of your imprint (optional, but recommended)

Notes: Please use the designation “owner” and not “managing director” for sole proprietors.

Contact data protection officer

First name, last name / Company
Street, house no.
Zip code, city
Country

Note: Only the e-mail address is mandatory, the other information is optional. Data protection officers need only be specified if they have been appointed. An order shall be placed pursuant to § Section 38 BDSG-Neu is already necessary for 20 or more employees who process personal data (for which an e-mail box is practically sufficient).

Processing overview

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

Note: The following information includes the typical data processed and categories of data subjects (these themselves, as well as the explanations in the brackets, are for clarification purposes only and may be adjusted or deleted).

Types of data processed

Inventory data (e.g., names, addresses).
Content data (e.g. entries in online forms).
Contact information (e.g., email, phone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. web pages visited, interest in content, access times).
Location data (information about the geographical position of a device or person).
Contract data (e.g. subject matter of the contract, term, customer category).
Payment data (e.g. bank details, invoices, payment history).

Categories of persons concerned

Business and Contractual Partners.
Interested parties.
Communication partner.
Customers.
Users (e.g., website visitors, users of online services).

Processing purposes

Assessment of creditworthiness and credit standing.
Provision of our online offer and user-friendliness.
Visit Action Evaluation.
Office and organizational procedures.
Cross-device tracking (processing of user data across devices for marketing purposes).
Direct marketing (e.g. by e-mail or postal mail).
Interest-based and behavioral marketing.
Contact requests and communication.
Conversion measurement (measurement of the effectiveness of marketing measures).
Profiling (creation of user profiles).
Remarketing.
Reach measurement (e.g. access statistics, recognition of returning visitors).
Safety measures.
Tracking (e.g., interest/behavioral profiling, use of cookies).
Provision of contractual services and customer service.
Managing and responding to inquiries.
Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

Credit report (decision based on a credit check).

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 (1) p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures

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

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

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

Note: Remove the reference to encryption if your offer is not encrypted. However, delivery of the website via https is to be considered mandatory.

Transfer and disclosure of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other entities, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

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

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

Cookies use

Cookies are small text files, or other memory tags, 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 of an online offer. Cookies can further be used for various purposes, e.g. for the purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users except where it is not required by law. In particular, consent is not required if the storage and reading of the information, i.e. including cookies, are absolutely necessary in order to provide the user with a telemedia service expressly requested by the user (i.e. our online offering). The revocable consent is clearly communicated to the users and contains the information about the respective cookie usage.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the aid of cookies depends on whether we ask users for consent. If the users consent, the legal basis of the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business management of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of 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 end device (e.g. browser or mobile app).
Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data 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 information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online offer). An objection to the use of cookies for online marketing purposes may also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further instructions on how to object in the context of the information on the service providers and cookies used.

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

Cookie settings/opposition:

If you use a cookie consent banner (which is recommended), you can enter the possibility to call it here (e.g. link or a so-called [Shortcode], which is automatically converted into a button/link by your software).

Notes on processing cookie data on the basis of consent: You should only leave this option (and otherwise delete it) if you obtain a “real” opt-in, i.e., user consent to the use of cookies (e.g., with so-called “cookie consent/consent/opt-in banners” or as part of a registration process).

Since a cookie opt-in is usually necessary according to the ECJ when using marketing tools frequently used in e-commerce (e.g. Google Analytics or Facebook Pixel), this option is preselected.

That is, until users give their consent, you do not use cookies (and do not use third-party services within your websites that themselves use cookies). Permissible is at most the use of necessary cookies that are expected by the users, such as a shopping cart function in the online store or local reach measurement with the tool Matomo.

Commercial and business services

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

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

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

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

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

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 will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the context of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers along with the access times in order to prove the registration and to prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the customer’s responsibility to back up their data upon termination of the customer’s account.

Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, 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 take into account the profiles of registered users, if available, together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g., as aggregated data).

Store and e-commerce: We process the data of our customers to enable them to select, purchase or order the selected products, goods and related 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, 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 identified 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 contact you.

Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Interested parties, business and contractual partners, customers.
Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to requests, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
Legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Note: Please remove the passage on customer account or analysis of customer data if you do not offer a customer account or do not analyze your customers’ data as described.

Payment service provider

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

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

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

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

Services used and service providers:

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.

Otherwise, adjust the list of services and providers as needed.

Credit check

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

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

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

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

Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
Affected persons: Customers, interested parties.
Purposes of processing: assessment of creditworthiness and credit standing.
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Automated decisions in individual cases: credit information (decision based on a credit check).

Services used and service providers:

Verband der Vereine Creditreform e.V.: Credit reference agency; Service provider: Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany; Website: https: //www.creditreform.de/; Privacy policy: https: //www.creditreform.de/datenschutz.

Note: Remove the credit check passage if you do not perform a credit check. Review and modify the list of service providers as needed. Checking the creditworthiness of a customer is permissible if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). In contrast, there is no risk of non-payment if the customer chooses the prepayment option, for example, or makes the payment via third-party providers such as Paypal.

It should also be noted that obtaining an automatic credit report is an “automated decision in individual cases” pursuant to §§ 3 and 4 of the German Data Protection Act. Article 22 GDPR, i.e. a legal decision without human involvement. This is permissible if the customer has consented or if this decision is necessary for the conclusion of the contract. Whether the decision is required has not yet been conclusively determined, but is widely held to be a given, including by the author of this sample.

However, if you want to eliminate any risk, you should obtain consent. Consent is also required if the credit report is already used to decide whether the “on account” option should be displayed at all. Because it could have been that the customer would have opted for prepayment or Paypal anyway and the credit check would not have been necessary. Such consent could, for example, read as follows:

I agree that a credit check is carried out in order to decide in an automated procedure (Art. 22 DSGVO) whether the option of purchase on account is offered. For more information on the credit check, the credit agencies used and the procedure, as well as the objection options, please refer to our [Link]privacy policy[/Link].

Provision of the online offer and web hosting

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

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

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

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

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

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 basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Note: If you have not already done so: Please ask the respective web hosts for a so-called “Auftragsverarbeitungsvertrag” (or “Data Processing Agreement”). This is required by law because the hoster collects personal data of website visitors for you.

Contact

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

The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries.

Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Communication partners, interested parties.
Purposes of processing: contact requests and communication, management and response to requests.
Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the requests and our statutory retention obligations.
Help Scout: contact request and communication management; 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 (ensuring level of data protection in case of processing in third countries): https://www.helpscout.com/company/legal/dpa/; order processing contract: https://www.helpscout.com/company/legal/dpa/.

Note: If third-party CRM systems are used, their providers should be named. Adjust this specification or remove the specified service provider. Furthermore, order processing contracts (or “Data Processing Agreement”) must be concluded with the providers. If the providers process the users’ data in the third country, special guarantees must be in place (e.g. standard contractual clauses).

Newsletter and electronic notifications

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

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

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

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

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

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

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

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

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the shipping service provider to monitor individual users. The evaluations rather serve us to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of its success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

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

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

Services used and service providers:

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/; order processing agreement: concluded with provider.
Mailchimp: email delivery 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/; Order processing contract: https: //mailchimp.com/legal/; Standard contractual clauses (ensuring level of data protection for processing in third countries): Inclusion in the order processing contract; Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.

Please delete the passage Newsletter if you do not send newsletters. Otherwise, adjust the list of services and providers as well as the newsletter content and performance measurement details as needed.

Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

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

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

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

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

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

Services used and service providers:

etracker: Web analytics/reach measurement; Service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; Website: https://www.etracker.com; Privacy policy: https: //www.etracker.com/datenschutz/; Order processing agreement: https: //www.etracker.com/av-vertrag/.
Google Analytics: web analytics, reach measurement and measurement of user flows; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Order processing agreement: https://business.safety.google/adsprocessorterms; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
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 offering (please refer to further details in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not yet create user profiles or store cookies, for example. Google only learns the user’s IP address, 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; order processing agreement:
https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring 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 data processed).
Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and recognizes returning users with the help of a so-called “digital fingerprint” that is stored anonymously and changed every 24 hours; with the “digital fingerprint”, user movements within our online offering are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that it is not possible to draw conclusions about the identity of individual users. User data collected through the use of Matomo is processed only by us and is not shared with third parties; website: https://matomo.org/.
Matomo: Matomo is software that is used for web analysis and reach measurement purposes. As part of the use of Matomo, cookies are generated and stored on the user’s terminal device. User data collected through the use of Matomo is processed only by us and is 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 maximum storage period of 13 months.

Please delete the passage Web analytics, monitoring and optimization if you do not use web analytics, monitoring and optimization tools on your website. Adjust the list of services and providers as needed.

Online marketing

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

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

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

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

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

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

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

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 about 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/behavior-based profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
Security measures: IP masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called “opt-out”) given to the providers. If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may restrict functions of our online offer. We therefore additionally recommend the following opt-out options, which are offered in summary form directed at respective territories:a) Europe: https://www.youronlinechoices.eu.
(b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Inter-area: https://optout.aboutads.info.

Services used and service providers:

Facebook pixel and targeting (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, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the web pages visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); 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 (ensuring level of data protection for processing in third countries): The “Facebook EU Data Transfer Supplement” (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of commissioned 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 Use of Facebook” (https://developers.facebook.com/terms) with regard to the autonomous processing of event data from Facebook in the context of ad placement; Further information: The “Data Processing Terms and Conditions” (https://www.facebook.com/legal/terms/dataprocessing/update) with respect to Event Data that Facebook processes on behalf to provide reporting and analytics to companies; Furthermore, the “Controller Addendum” is deemed to be a joint responsibility agreement (Article 26 (1) sentence 3 of the GDPR), which is relevant in the case of Facebook’s own processing of Event Data for purposes of targeting and improving and securing Facebook’s products.
Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner in order to only present users with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has expressed interest 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; Other information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Google Advertising Products Data Processing Terms: Information on services Data processing terms and conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; If Google acts as a processor, data processing terms and conditions 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 method “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called “conversion”). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a so-called “conversion tracking tag”. However, we ourselves do not receive any information that can be used to identify users; 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 conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Please delete the Online marketing passage if you do not use any online marketing tools on your website. Adjust the list of services and providers as needed. Please keep in mind that the use of marketing services on the website usually requires a cookie opt-in.

Presence in social networks (social media)

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

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

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

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

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

Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https: //instagram.com/about/legal/privacy.
Facebook 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 “Fanpage”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by the users (e. g. B. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the “Site Insights Information”(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 (ensuring level of data protection in case of processing in third countries):https://www.facebook.com/legal/EU_data_transfer_addendum; Additional Information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.
LinkedIn: social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; standard contractual clauses (ensuring level of data protection for processing in third countries): https: //legal.linkedin.com/dpa; opt-out: https: //www.linkedin.com/psettings/guest-controls/retargeting-opt-out; order processing contract: 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/de/privacy-policy; further information: Pinterest Data Sharing Annex (ANNEX A): https://business.pinterest.com/de/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/de/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; 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/de/datenschutzerklaerung.

Customize the list of social networks as needed.

Plugins and embedded functions and content

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

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

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 a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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 experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to requests.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

Facebook plugins and content: Facebook Social Plugins and Content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ – We are jointly responsible withMeta Platforms Ireland Limited for the collection or receipt in the course of any transmission (but not the further processing) of “Event Data” that Facebook collects or receives in the course of any transmission by means of the Facebook social plugins (and content embedding features) running on our Online Service for the following purposes: a) Displaying content as well as advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalization of features and content (e.g., improving the identification of which content or advertising information is likely to be of interest to users). We have entered into a special agreement with Facebook (“Responsible Party Addendum”, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not done under shared responsibility, but rather on the basis of a data processing agreement (“Data Processing Terms “, https://www.facebook.com/legal/terms/dataprocessing) , the “Data security conditions” (https://www.facebook.com/legal/terms/data_security_terms) as well as with regard to processing in the U.S. based on 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 user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
Google Maps: We integrate the maps of the service “Google Maps” of the provider Google. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed as part of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called “bots”). Data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on web pages, web pages previously visited, interactions with ReCaptcha on other web pages, cookies in some circumstances, and results of manual recognition processes (e.g. answering questions asked or selecting objects in images); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Opt-out plugin: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Twitter plugins and content: Twitter plugins and buttons – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering 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/de; 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; opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad Display Settings: 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; Opt-Out: We point out that Vimeo may 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=de) or Google’s settings for data use for marketing purposes(https://adssettings.google.com/).

Please delete the passage Plugins and embedded functions as well as content if you do not use plugins or embedded functions as well as content within your website. Otherwise, adjust the list of services and providers as needed.

Data deletion

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

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

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Modification and update of the privacy policy

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

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

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

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

Definitions

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

Visit action evaluation: “Visit action evaluation” (English “Conversion Tracking”) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing activities take place and then retrieved again on the target website. For example, it allows us to track whether the ads we placed on other websites were successful).
Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. According to Art. 22 GDPR, such automated decisions are only permitted if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
Cross-device tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g. cell phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
IP masking: IP masking is a method of deleting the last octet, i.e., the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when users’ potential interests in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting certain websites and staying on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing activities take place and then retrieved again on the target website. For example, we can track whether the ads we have placed on other websites have been successful.
Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiling: Profiling” is any type of automated processing of personal data that consists of using such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behavior or interests in certain information, such as web page content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
Remarketing: “Remarketing” or “retargeting” is when, for example, for advertising purposes, a note is made of which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and functions for location determination. Location data is used to indicate at which geographically determinable position on 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: We speak of “tracking” when the behavior of users can be traced across several online offerings. As a rule, with regard to the online offers used, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information may subsequently be used, for example, to display advertisements to users that are likely to match their interests.
Controller: a “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is wide-ranging and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.
Targeting: Targeting (or “custom audiences”) is when target groups are determined for advertising purposes, e.g., display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be inferred that this user is interested in advertisements for similar products or the online store where he viewed the products. In turn, we speak of “lookalike audiences” (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.

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Responsible

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Processing overview

Types of data processed

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Processing purposes

Automated decisions in individual cases

Relevant legal bases

Security measures

Transfer and disclosure of personal data

Data processing in third countries

Cookies use

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Credit check

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Contact

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Online marketing

Presence in social networks (social media)

Plugins and embedded functions and content

Data deletion

Modification and update of the privacy policy

Rights of the data subjects

Definitions

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