Data protection regulations
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") 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, 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.
Status: August 30, 2023
Table of contents
- Preamble
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- International data transfers
- Deletion of data
- Rights of the data subjects
- Use of cookies
- Payment procedure
- Provision of the online offer and web hosting
- Blogs and publication media
- Contact and inquiry management
- Chatbots and chat functions
- Newsletter and electronic notifications
- Competitions and contests
- Web analysis, monitoring and optimization
- Online marketing
- Customer reviews and evaluation process
- Presence in social networks (social media)
- Plugins and embedded functions and content
- Amendment and updating of the privacy policy
- Definitions of terms
Person responsible
Dr. Emi Arpa Skin GmbH | Fasanenstraße 65 | 10719 Berlin
Commercial Register Berlin Charlottenburg | HRB 248486B
Value added tax ID (VAT-ID): DE358543091
Managing directors: Dr. med. Emi Arpa, Sebastian Dahlem
E-mail: hello@dr-emiskin.de +49 (0)30 88675777
Persons authorized to represent the company:
Sebastian Dahlem
E-mail address: hello@dr-emiskin.de
Imprint:
www.dr-emiskin.de/pages/impressum
Relevant legal bases
Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR): The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.
Relevant legal basis according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Swiss Federal Act on Data Protection ("Swiss FADP" for short). This also applies if our processing of your data otherwise affects you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not stipulate (unlike the GDPR, for example) that a legal basis for the processing of personal data must be specified. We only process personal data if the processing is lawful, is carried out in good faith and is proportionate (Art. 6 para. 1 and 2 of the Swiss FADP). Furthermore, we only obtain personal data for a specific purpose that is recognizable to the data subject and only process it in such a way that it is compatible with these purposes (Art. 6 para. 3 of the Swiss FADP).
Reference to validity of GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms "processing" of "personal data", "overriding interest" and "sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data", "legitimate interest" and "special categories of data" used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Inventory data.
- Payment data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Contact information (Facebook).
- Event data (Facebook).
Categories of affected persons
- Customers.
- Interested parties.
- Communication partner.
- Users.
- Competition and contest participants.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Contact requests and communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Remarketing.
- Conversion measurement.
- Click tracking.
- Target group formation.
- A/B tests.
- Managing and responding to inquiries.
- Organizing competitions and contests.
- Feedback.
- Heatmaps.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Information technology infrastructure.
Security measures
We take appropriate technical and organizational measures 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, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as 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. 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.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as "IP masking"). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it much more difficult to identify a person by their IP address.
TLS encryption (https): We use TLS encryption to protect your data transmitted via our online offering. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
As part of our processing of personal data, data may be transferred to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Shopify: In order to fulfill the order and thus provide the service, the data is transmitted to our store system Shopify.
shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online stores, websites, their offers and content, community elements, purchase and payment processes, customer communication as well as analysis and marketing; service provider: Shopify International Limited, Victoria Buildings, 2nd Floor,1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.shopify.deData protection declaration: https://www.shopify.de/legal/datenschutz.
Billbee: We use the Billbee tool to create customer invoices.
Billbee: Billbee Gesellschaft mit beschränkter Haftung, Arolser Str. 10, 34477 Twistetal, Managing Directors authorized to represent the company: Jan Krause, David Pohlmann, Register Court: Korbach Local Court, Register number: HRB 2482, Registered office of the company: Twistetal; Website:https://www.billbee.io/Data protection declaration: https://www.billbee.io/rechtliches/datenschutz.
HIVE: We use the fulfillment service provider HIVE to process our orders and send them to the customer.
Hive: fulfillment service provider, Hive Technologies GmbH, Rosenstraße 16-17, 10178 Berlin, Germany, VAT Number/Sales Tax: DE330492525; Website: https://www.hive.app/de/Privacy policy: https://www.hive.app/de/datenschutz.
GTC - Note (conclusion of contract):
"For deliveries to Switzerland, the purchase contract is concluded between the buyer and MeinEinkauf AG, St. Gallen (CHE-331.561.017 VAT) in accordance with our GTC. The latter also handles customs clearance, invoicing and delivery in Switzerland. This service is included in the purchase price and any shipping costs. In order to ensure smooth delivery to Switzerland, we would like to point out for reasons of transparency that MeinEinkauf GmbH in DE-Konstanz (DE285677365) is also involved in the retail chain. This does not result in any additional costs for the buyer."
International data transfers
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, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you which service providers we use are certified under the Data Privacy Framework as part of the data protection information.
Disclosure of personal data abroad: In accordance with the Swiss Data Protection Act (DSG), we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss DSG). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country.
According to Art. 16 of the Swiss DPA, exceptions may be made for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies 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 that 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 defense of legal claims or to protect the rights of another natural or legal person.
As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain access to this data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller
- Complaint to a supervisory authority: In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of 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.
Rights of data subjects under the Swiss DPA:
As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:
- Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to receive the information necessary for you to exercise your rights under this law and to ensure transparent data processing.
- Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to analyze visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offer). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies.
Information on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users give their consent, the legal basis for processing their data is the consent given. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and improving its usability) or, if this is done in the context of fulfilling 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 period: A distinction is made between the following types of cookies with regard to the storage period:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.
General information on revocation and objection (so-called "opt-out"): Users can revoke the consent they have given at any time and object to processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ can be declared.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server 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: Consent may be stored for up to two years. A pseudonymous user identifier is created 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; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- BorlabsCookie: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user's device.
Payment procedure
As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively referred to as "payment service providers").
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total 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 that we do not receive any account or credit card-related information, but only information with confirmation or negative information about 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. Please refer to the general terms and conditions and the data protection information of the payment service providers.
Payment transactions are subject to the terms and conditions and the data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other rights of data subjects.
- Processed data types: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Contact data (e.g. e-mail, telephone numbers).
- Persons affected: Customers. Interested parties.
- Purposes of the processing: Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- American Express: Payment services (technical connection of online payment methods); Service provider: American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.americanexpress.com/de. Privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.
- Apple Pay: Payment services (technical connection of online payment methods); Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.apple.com/de/apple-pay/. Privacy policy: https://www.apple.com/legal/privacy/de-ww/.
- Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.giropay.de. Privacy policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
- Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://pay.google.com/intl/de_de/about/. Privacy policy: https://policies.google.com/privacy.
- Klarna: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.klarna.com/de. Privacy policy: https://www.klarna.com/de/datenschutz.
- Mastercard: Payment services (technical connection of online payment methods); Service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.mastercard.de/de-de.html. Privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
- PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de. Privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
- Store Pay (Shopify): Payment services (technical connection of online payment methods); Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
- Visa: Payment services (technical connection of online payment methods); Service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, UK; Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.visa.de. Privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms); 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 the contract, term, customer category).
- Data subjects: Users (e.g. website visitors, users of online services). Customers.
- Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); security measures. Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online services on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, 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 event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability;
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified. - E-mail dispatch and hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online stores, websites, their offers and content, community elements, purchase and payment processes, customer communication as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor,1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Processed data types: 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 and procedural data (e.g. IP addresses, time data, identification numbers, consent status); payment data (e.g. bank details, invoices, payment history). Contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Users (e.g. website visitors, users of online services). Customers.
- Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness; security measures. Managing and responding to inquiries.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
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Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process user data for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies in order to avoid multiple votes.
The personal information provided in the comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online stores, websites, their offers and content, community elements, purchase and payment processes, customer communication as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor,1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
Contact and inquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
- Processed data types: 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner.
- Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Klaviyo: Email and SMS marketing platform; Service provider: Klaviyo, 225 Franklin St., Boston, Massachusetts 02110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.klaviyo.com/; Privacy policy: https://www.klaviyo.com/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
Chatbots and chat functions
We offer online chats and chatbot functions (collectively referred to as "chat services") as a means of communication. A chat is an online conversation conducted with a certain degree of timeliness. A chatbot is software that answers users' questions or informs them about messages. If you use our chat functions, we may process your personal data.
If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove these in accordance with legal requirements.
We would like to point out to users that the respective platform provider may find out that and when users communicate with our chat services and may collect technical information about the user's device used and, depending on their device settings, location information (so-called metadata) for the purpose of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e. e.g. information on who has communicated with whom) may be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their provisions, to which we refer for further information.
If users declare their willingness to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information for the future at any time. The chatbot informs users how and with which terms they can unsubscribe from the messages. By unsubscribing from the chatbot messages, user data is deleted from the list of message recipients.
We use the aforementioned data to operate our chat services, e.g. to address users personally, to answer their queries, to transmit any requested content and also to improve our chat services (e.g. to "teach" chatbots answers to frequently asked questions or to recognize unanswered queries).
Notes on legal bases: We use the chat services on the basis of consent if we have previously obtained permission from users to process their data in the context of our chat services (this applies to cases in which users are asked for consent, e.g. so that a chatbot can send them regular messages). If we use chat services to answer users' inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services on the basis of our legitimate interests in optimizing the chat services, their cost-effectiveness and enhancing the positive user experience.
Revocation, objection and deletion: You can revoke your consent at any time or object to the processing of your data in the context of our chat services.
- Processed data types: 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Communication partner.
- Purposes of the processing: Contact requests and communication; managing and responding to requests. Direct marketing (e.g. by e-mail or post).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing operations, procedures and services:
- LiveChat: Chatbot and assistance software and related services; Service provider: LiveChat Inc, One International Place, Suite 1400 Boston, Massachusetts 02110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.livechatinc.com/de; Privacy policy: https://www.livechatinc.com/legal/privacy-policy/. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
Newsletter and electronic notifications
We only send newsletters, emails and other electronic notifications (hereinafter "newsletter") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people's e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of verifying that it is carried out properly. 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 sending system.
Contents:
Information about us, our products & services, promotions and offers.
- Processed data types: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Usage data (e.g. websites visited, interest in content, access times).
- Affected persons: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- 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 unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing operations, procedures and services:
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Measurement of opening and click rates: The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help 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 measurement of opening rates and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of the user's consent.
Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted;
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). - Reminder emails for the order process: If users do not complete an order process, we can remind users of the order process by email and send them a link to continue it. This function can be useful, for example, if the purchase process could not be continued due to a browser crash, oversight or forgetting. Sending is based on consent, which users can revoke at any time; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Klaviyo: Email and SMS marketing platform; Service provider: Klaviyo, 225 Franklin St., Boston, Massachusetts 02110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.klaviyo.com/; Privacy policy: https://www.klaviyo.com/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
Competitions and contests
We process personal data of participants in competitions and contests only in compliance with the relevant data protection regulations, insofar as the processing is contractually required for the provision, execution and handling of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).
If participants' contributions are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or winners or reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.
If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants as part of the competition and that inquiries regarding the competition should be directed to us.
The participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are to be expected. In principle, participants' data will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for longer, e.g. in order to answer queries about the prizes or to fulfill the prize; in this case, the retention period depends on the type of prize and is up to three years for items or services, e.g. in order to be able to process warranty claims. Furthermore, the participants' data may be stored for longer, e.g. in the form of reporting on the competition in online and offline media.
If data was also collected for other purposes as part of the competition, its processing and the retention period are based on the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).
- Processed data types: Inventory data (e.g. names, addresses); content data (e.g. entries in online forms). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Affected persons: Competition and contest participants.
- Purposes of the processing: Carrying out competitions and contests.
- Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Registration for and participation in events
From time to time we organize events to which we invite you. Participation in these events regularly requires prior registration or login. We also process data for the implementation (e.g. admission handling) of the event and for reporting on it.
In detail:
- Processed data types:
Event dataWe process the following data in particular for the preparation and (digital) dispatch of invitations and the organization of the event: Salutation, title, surname, first name, position, company, address data (city, street, zip code), e-mail address, data on any accompanying persons: Salutation, title, surname, first name as well as information on affiliations and personal relationships with each other, data that you may send us in the course of further correspondence, and in the event of acceptance or rejection of participation in the event: registration status and, if applicable, registration code.
Log file dataWe process the following data in particular for the digital registration or cancellation of the event: IP address, product and version information about the browser used and the operating system (so-called user agent) of the device with which you access our website, date and time of the request (so-called timestamp), http status and the amount of data transferred as part of your request.
Photo and moving image recordingsFor the (post-event) reporting on the event, photographers commissioned by us will take photos and moving images during the event. This includes photographs of the overall event as well as individual persons or groups of persons. If you are recognizable in these, we may collect and process the following data: Photographs and moving images, names.
- Affected persons: Persons who are invited to the event and/or participate in the event.
Preparation of the event and sending invitations to the event: With the exception of registration status information and, if applicable, registration code, we store, check, organize and, if necessary, correct your event data. The purpose is the planning, preparation, organization and implementation of the event.
We use the e-mail address you have provided us with to send you an invitation to the event. The purpose is to invite you to participate in the event and to enable you to attend.
We will also use your e-mail address to send you further information, reminders or notices about the event.
We also store your contact details so that we can invite you to other events if necessary.
Registration process: You must register to take part in the event. After receiving the invitation e-mail, you have the option of clicking on a link in the invitation e-mail to register or deregister for the event.
Click on the link to open our registration tool. When you access the registration tool, we collect and store your log file data. We collect and store your log file data in order to provide you with the registration tool and to ensure its functionality. In addition, the log file data is used to ensure the security of our information technology systems (e.g. to detect attacks) and to analyze capacity utilization and eliminate errors.
If you register or cancel your registration for the event via the registration tool, we will link the event data you have stored with us to the registration or cancellation for the event and store the registration or cancellation information as well as any other information (e.g. on accompanying persons) to your event data. The purpose of this processing of your event data is to organize and plan the event, to ensure that everything runs smoothly and to ensure proper admission control and security on site.
Contacting usIf you use the e-mail address provided via the registration tool or in the invitation e-mail to send us inquiries, we will process your personal data transmitted to us with the inquiry. The purpose of the processing is to answer your inquiries and provide you with information.
Admission handling at the event: We carry out an admission check at the event venue. As part of the admission check, we compare your name with your event data stored with us. The purpose of this is to ensure that the event is carried out properly and safely and to control admission to the event.
Creation and publication of photos and moving images: During the event, we will take photographs and moving images in which you may be recognizable. We may store and publish individual photographs and moving images on our company intranet, on our website (https://dr-emi.de) and on our social media channels (e.g. Instagram, YouTube, TikTok). The purpose is to document and report on the event, to present our company to the outside world and to support our PR and public relations work. We may pass on selected photos and moving images to the media for their reporting as press material.
- Legal basis: Balancing of interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Our legitimate interests:
Event data: Ensuring the proper execution of the event and safe participation in the event.
Log file data: Provision of a registration tool and thus a simple and efficient login and logout.
Photo and moving image recordings: Documentation of and reporting on the event, positive external image of our company and external communication.
- Duration of storage: Your above-mentioned data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
For the log file data this is the case when the respective session has ended. Storage beyond this is possible for technical reasons. In this case, we delete or hash the respective IP address so that it is no longer possible to identify the accessing client and the data contained can no longer be linked to a specific person.
In addition, we will delete your event data fourteen days after the event has taken place. Your data may continue to be stored by us after the end of the event because its processing is either necessary for another purpose and/or we can use another legal basis for its storage. In particular, we store your name and contact details for invitations to further events. The storage period or duration of publication of the photo and moving image recordings depends on their information value and the general information interest in the event. The internal long-term archiving of individual photographs and moving image recordings is carried out with limited processing in order to protect our legal copyright claims to the photographs and moving image recordings created by us and for possible later publication, for example as part of the company history.
- Necessity of the provision: The provision of your data is neither legally nor contractually required. However, the collection and storage of log file data is necessary for the operation of the registration tool. The provision of your event data is also necessary for the invitation and registration/deregistration for and participation in the event. Failure to provide the above personal data may result in disadvantages for you. For example, this could result in you not being able to register for the event and/or participate in the event.
- Possibility of objection: You can object to the processing of your event data and log file data at any time in accordance with Art. 21 GDPR by sending an email to [...]. You can object to the creation and publication of photographs and moving image recordings concerning you in accordance with Art. 21 GDPR by informing a photographer present at the event that you do not wish to be photographed or by sending an email to [...].
Web analysis, monitoring and optimization
Web analysis (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, recognize at what time our online offer or its functions or content are most frequently used or invite reuse. We can also understand which areas require optimization.
In addition to web analysis, we may also use test procedures, e.g. to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, location data may also be processed.
The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, 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 processes.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Remarketing; target group formation; reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; tracking (e.g. interest/behavioral profiling, use of cookies); click tracking; A/B tests. Heatmaps (mouse movements by users that are summarized into an overall picture).
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Optimize: Software for the analysis and optimization of online offers based on feedback functions as well as pseudonymous measurements and analyses of user behavior, which may include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://optimize.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms). Further information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
- Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city's inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms); Option to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: https://adssettings.google.com/authenticated. Further information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
- Target group formation with Google Analytics: We use Google Analytics to display the ads placed by Google and its partners within advertising services only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called "remarketing" or "Google Analytics audiences"). With the help of remarketing audiences, we also want to ensure that our ads correspond to the potential interest of users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Legal basis: https://business.safety.google/adsprocessorterms/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
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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 information in this privacy policy). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies, for example. 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; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract:
https://business.safety.google/adsprocessorterms. Basis for third country transfer: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://business.safety.google/adsprocessorterms). - Hotjar Observe: Software for the analysis and optimization of online offers on the basis of pseudonymous measurements and analyses of user behavior, which may include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online offer (so-called heat maps and recordings); Service provider: Hotjar Ltd, 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta ; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.hotjar.com; Privacy policy: https://www.hotjar.com/legal/policies/privacy; Deletion of data: The cookies Hotjar uses have different "lifespans"; some remain valid for up to 365 days, some only during the current visit; Cookie Policy: https://www.hotjar.com/legal/policies/cookie-information. Option to object (opt-out): https://www.hotjar.com/legal/compliance/opt-out.
Online marketing
We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of 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 information relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (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. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze 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.
- Processed data types: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); event data (Facebook) ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means), for example, and relates to individuals or their actions; the data includes, for example, information about visits to websites, interactions with content, installations of apps, purchases of products, etc.; the event data is used to form target groups for content and advertising information, etc.; the event data is processed for the purpose of forming target groups for content and advertising information. The data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data will be deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account); contact information (Facebook) ("contact information" is data that (clearly) identifies data subjects, such as names, e-mail addresses and telephone numbers, which can be transmitted to Facebook, e.g. via Facebook pixels or uploads for matching purposes for the purpose of creating custom audiences. The contact information is deleted after matching for the purpose of creating target groups).
- 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/behavioral profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; remarketing. Click tracking.
- Security measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
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Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for the 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.
Further information on processing operations, procedures and services:
- Meta pixel and target group formation (custom audiences): With the help of the Meta pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for the Meta company to determine the visitors of our online offer as a target group for the display of advertisements (so-called "meta ads"). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called "audience network"). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Meta (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a meta ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and audience targeting on the basis of the joint controllership agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Meta - Formation of target groups via data upload: Formation of target groups for marketing purposes - We transmit contact information (names, e-mail addresses and telephone numbers) in list form to Meta for the purpose of forming target groups (so-called "custom audiences") for the display of content and advertising information based on the presumed interests of users. The transmission and comparison with data available at Meta does not take place in plain text, but as so-called "hash values", i.e. mathematical representations of the data (this method is used, for example, to store passwords). The contact information is deleted after matching for the purpose of creating target groups; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfer: EU-US Data Privacy Framework (DPF), standard contractual clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
- Facebook Ads: Placement of ads within the Facebook platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Possibility of objection (opt-out): We refer to the data protection and advertising settings in the user's profile on the Facebook platform as well as in the context of Facebook's consent procedure and Facebook's contact options for exercising information and other data subject rights in Facebook's privacy policy. Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the Joint Controller Agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Google Ads and conversion measurement: Online marketing process for the purpose of placing content and ads within the service provider's advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether users have taken them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and no personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Google Ads Remarketing: Google Remarketing, also known as retargeting, is a technology that allows users who use an online service to be added to a pseudonymous remarketing list so that users can be shown ads on other online offers based on their visit to the online service; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices. Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
- Extended conversions for Google Ads: When customers click on our Google ads and subsequently use the advertised service (so-called "conversion"), the data entered by the user, such as the e-mail address, name, home address or telephone number, can be transmitted to Google. The hash values are then compared with existing Google accounts of the users in order to better evaluate and improve the interaction of the users with the ads (e.g. clicks or views) and thus their performance; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Website: https://support.google.com/google-ads/answer/9888656.
- Instagram ads: Placement of advertisements within the Instagram platform and evaluation of ad results; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF); Possibility of objection (opt-out): We refer to the data protection and advertising settings in the user's profile on the Instagram platform as well as in the context of Instagram's consent procedure and Instagram's contact options for exercising information and other data subject rights in Instagram's privacy policy. Further information: Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and targeting on the basis of the Joint Controller Agreement ("Controller Addendum", https://www.facebook.com/legal/controller_addendum). The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Taboola: Integration of personalized content and content recommendations; Service provider: Taboola, Inc. 16 Madison Square West 7th Floor New York, New York 10010, USA; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.taboola.com/de; Privacy policy: https://www.taboola.com/privacy-policy; Data processing agreement: Provided by the service provider; Basis for third country transfer: Standard contractual clauses (Provided by the service provider); Deletion of data: Taboola retains user information collected directly for the purpose of serving ads for a maximum of eighteen (18) months after the user's last interaction with the Taboola Services and anonymizes it by removing personal identifiers or aggregating the data. Taboola stores anonymous or aggregated data that cannot identify a person or device and is used for reporting and analysis purposes as long as commercially necessary. Possibility of objection (opt-out): https://www.taboola.com/privacy-policy#user-choices-and-optout.
- UTM parameter: Analyzing sources and user actions based on an extension of web addresses referring to us with an additional parameter, the "UTM" parameter. For example, a UTM parameter "utm_source=platformX &utm_medium=video" can tell us that a person has clicked on the link on platform X within a video. The UTM parameters provide information about the source of the link, the medium used (e.g. social media, website, newsletter), the type of campaign or the content of the campaign (e.g. post, link, image and video). We can use this information, for example, to check our visibility on the internet or the effectiveness of our campaigns; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Customer reviews and evaluation process
We participate in review and rating procedures in order to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers' data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.
In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer's consent. This data is used solely to verify the authenticity of the user.
- Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history). Contact data (e.g. e-mail, telephone numbers).
- Persons affected: Customers. Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form); marketing. Provision of contractual services and fulfillment of contractual obligations.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
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Rating widget: We integrate so-called "rating widgets" into our online offering. A widget is a functional and content element integrated into our online offering that displays variable information. It can, for example, be displayed in the form of a seal or comparable element, sometimes also called a "badge". Although the corresponding content of the widget is displayed within our online offering, it is retrieved from the servers of the respective widget provider at that moment. Only in this way can the current content always be shown, especially the current rating. For this purpose, a data connection must be established from the website accessed within our online offering to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) that is necessary for the content of the widget to be delivered to the user's browser.
Furthermore, the widget provider receives information that users have visited our website. This information can be stored in a cookie and used by the widget provider to recognize which online offers that participate in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes;
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - shopify: Platform via which e-commerce services are offered and carried out. The services and processes carried out in connection with them include, in particular, online stores, websites, their offers and content, community elements, purchase and payment processes, customer communication as well as analysis and marketing; Service provider: Shopify International Limited, Victoria Buildings, 2nd Floor,1-2 Haddington Road, Dublin 4, D04 XN32, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.shopify.de. Privacy policy: https://www.shopify.de/legal/datenschutz.
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 the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The user 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 user's computer, in which the user's usage behavior and interests are stored. Furthermore, data can also be stored in the user 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 description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user's data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: 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 and process data (e.g. IP addresses, time data, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy.
- Facebook pages: Profiles within the Facebook social network - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "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 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, known as "Page Insights", for page operators to help them understand how people interact with their pages and 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 regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum). Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- TikTok: Social network / video platform; Service provider: TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, United Kingdom, EC1A 9HP; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.tiktok.com. Privacy policy: https://www.tiktok.com/de/privacy-policy.
- Vimeo: Social network and video platform; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://vimeo.com. Privacy policy: https://vimeo.com/privacy.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Possibility of objection (opt-out): https://adssettings.google.com/authenticated.
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags can be used to analyze 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 offer, as well as being linked to such information from other sources.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Inventory data (e.g. names, addresses); Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Event data (Facebook) ("event data" is data that can be transmitted by us to Facebook e.g. via Facebook pixels (via apps or in other ways) can be transmitted by us to Facebook and relate to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences). Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.)
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offer and user-friendliness; provision of contractual services and fulfillment of contractual obligations; profiles with user-related information (creation of user profiles). Marketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Facebook plugins and content: Facebook social plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can 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 context of a transmission (but not the further processing) of "event data" that Facebook collects or receives in the context of a transmission by means of the Facebook social plugins (and embedding functions for content) that are executed on our online offer for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Facebook social plugins). (e.g. addressing users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing) , the "Data security conditions" (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses ("Facebook-EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy. Basis for third country transfer: EU-US Data Privacy Framework (DPF).
- Instagram plugins and content: Instagram plugins and content - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt in the context of a transmission (but not the further processing) of "event data" that Facebook collects using Instagram functions (e.g. embedding functions for content) that are executed on our online offer or receives in the context of a transmission for the following purposes: a) Display of content and advertising information that corresponds to the presumed interests of the users; b) Delivery of commercial and transaction-related messages (e.g. addressing users via Instagram). (e.g. addressing users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g. improving the recognition of which content or advertising information presumably corresponds to the interests of users). We have concluded a special agreement with Facebook ("Controller Addendum", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out within the framework of joint responsibility, but on the basis of a data processing agreement ("Data Processing Terms", https://www.facebook.com/legal/terms/dataprocessing) , the "Data Security Conditions" (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; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com. Privacy policy: https://instagram.com/about/legal/privacy.
- reCAPTCHA: We integrate the "reCAPTCHA" function in order 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"). 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 and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Data processing is carried out on the basis of our legitimate interest in protecting our online offering from abusive automated crawling and spam; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: https://adssettings.google.com/authenticated.
- YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Basis for third country transfer: EU-US Data Privacy Framework (DPF). Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=deSettings for the display of advertisements: 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; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Order processing contract: https://vimeo.com/enterpriseterms/dpa; Basis for third country transfer: Standard Contractual Clauses (https://vimeo.com/enterpriseterms/dpa). Possibility of objection (opt-out): We would like to point out that Vimeo may use Google Analytics and refer you to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for the use of data for marketing purposes (https://adssettings.google.com/).
Amendment and updating of the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will 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 organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- A/B tests: A/B tests are used to improve the user-friendliness and performance of online offers. For example, users are shown different versions of a website or its elements, such as input forms, on which the placement of the content or the labels of the navigation elements can differ. The behavior of the users, e.g. longer time spent on the website or more frequent interaction with the elements, can then be used to determine which of these websites or elements are more likely to meet the needs of the users.
- Heatmaps: "Heatmaps" are mouse movements of users that are summarized into an overall picture, which can be used, for example, to recognize which website elements are preferred and which website elements users prefer less.
- Click tracking: Click tracking allows us to keep track of users' movements within an entire online offering. As the results of these tests are more accurate if the user's interaction can be tracked over a certain period of time (e.g. so that we can find out whether a user likes to return), cookies are usually stored on the user's computer for these test purposes.
- Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors, for example. For the purposes of reach analysis, 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: The term "remarketing" or "retargeting" is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: The term "tracking" is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Controller: The "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 on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
- Target group formation: Custom audiences are defined as target groups for advertising purposes, e.g. the display of advertisements. 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 store in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.