Privacy Policy

Data protection

introduction

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

The terms used are not gender specific.

Status: 04/04/2021

Contents overview

Responsible person

Dieter Parcharidi
Kommandantenstrasse 71
10117 Berlin
0176 566 48 228

Authorized representatives: Dieter Parcharidi

E-mail address: info@xn--cbd-l24-d1a.de

Imprint: https://xn--cbd-l24-d1a.de/impressum

Overview of the 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 (e.g. names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact details (e.g. email, telephone numbers).
  • Meta / communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (information on the geographical position of a device or a person).
  • Contract data (e.g. subject of the contract, duration, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Interested persons.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Assessment of creditworthiness and creditworthiness.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking (e.g. interest- / behavior-related profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Management and answering of inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

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

Relevant legal bases

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

  • Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR) – The data subject has given their consent to the processing of their personal data for a specific purpose or for several specific purposes.
  • Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b.GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures that are carried out at the request of the data subject.
  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR) – The processing is necessary to fulfill a legal obligation to which the person responsible is subject.
  • Legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR) – The processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, outweigh this.

Safety 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 type, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, the deletion of data and reactions to the threat to the data. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

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

Transmission and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or they are disclosed to them. The recipients of this data can include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

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

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

Use of cookies

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

A distinction is made between the following types of cookies and functions:

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

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

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

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

Processing of cookie data on the basis of consent : Before we process or have data processed in the context of the use of cookies, we ask the user for consent that can be revoked at any time. Before the consent has not been given, cookies may be used, which are absolutely necessary for the operation of our online offer.

Cookie settings / objection option:

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

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Commercial and business services

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

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

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

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. basically after 4 years, unless the data is stored in a customer account, e.g. as long as it has to be kept for archiving reasons for legal reasons (e.g. for Tax purposes usually 10 years). We delete data disclosed to us by the contractual partner in the context of an order in accordance with the specifications of the order, generally after the order has ended.

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

Customer account : Contractual partners can create an account within our online offer (e.g. customer or user account, “customer account” for short). If it is necessary to register a customer account, contractual partners will be informed of this as well as the information required for registration. The customer accounts are not public and cannot be indexed by search engines. As part of the registration as well as subsequent logins and uses of the customer account, we save the IP addresses of the customers along with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, subject to their retention being required for legal reasons. It is the customer’s responsibility to secure their data if the customer account is terminated.

Economic analysis and market research : For business reasons and in order to be able to recognize market trends, wishes of the contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of ours are included in the group of persons concerned Online offers can fall.

The analyzes are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users including their details, e.g. on services used. The analyzes serve us alone and are not disclosed externally, unless they are anonymous analyzes with summarized, i.e. anonymized, values. Furthermore, we take the privacy of users into account and process the data for analysis purposes as pseudonymously and, if possible, anonymously (e.g. as summarized data).

Shop and e-commerce : We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution for our customers. We use the services of banks and payment service providers to process payment transactions. The information required is marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact details (e.g. e-mail, telephone numbers), 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 data (e.g. device information, IP addresses).
  • Affected people: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact inquiries and communication, office and organizational procedures, administration and answering of inquiries, security measures, visit action evaluation, interest-based and behavior-related marketing, profiling (creation of user profiles).
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit.f. GDPR).

Payment service provider

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

The data processed by the payment service provider includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. The data may be transmitted to credit agencies by the payment service provider. The purpose of this transmission is to check your identity and creditworthiness. For this we refer to the terms and conditions and the data protection information of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service provider apply, which can be called up within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of rights of revocation, information and other 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, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information , IP addresses).
  • Affected people: Customers, prospects.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit.

Used services and service providers:

Credit check

If we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right to obtain an identity and credit report for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests ) to obtain.

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

The decision as to whether we will make advance payments is made in accordance with Art. 22 GDPR solely on the basis of an automated decision on a case-by-case basis, which our software makes on the basis of information from the credit agency.

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

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact details (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category).
  • Affected people: Customers, prospects.
  • Purposes of processing: Assessment of creditworthiness and creditworthiness.
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Automated decisions in individual cases: Credit information (decision based on a credit check).

Used services and service providers:

Provision of the online offer and web hosting

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

The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hosting : The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of emails (e.g. the providers involved) and the content of the respective emails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted while they are being transported, but (if no so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and receipt on our server.

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

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the load on the server and its stability.

  • Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

contact

When contacting us (e.g. via the contact form, email, telephone or via social media), the details of the inquiring person are processed, insofar as this is necessary to answer the contact inquiries and any requested measures.

The answering of contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre) contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP Addresses).
  • Affected people: Communication partner, interested parties.
  • Purposes of processing: Contact inquiries and communication, administration and answering of inquiries.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit.

Used services and service providers:

Newsletters and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.

To register for our newsletters, it is generally sufficient to provide your email address. However, we can ask you to provide a name for the purpose of addressing you personally in the newsletter, or to provide further information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with someone else’s e-mail address. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

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

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving that it has proceeded 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 mailing system.

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

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

Analysis and success measurement: The newsletters contain a so-called “web beacon”, ie a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from its server. As part of this retrieval, technical information is initially collected , such as information about the browser and your system, as well as your IP address and the time of access.

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

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

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

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta / communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected people: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opposition option (opt-out): You can cancel the receipt of our newsletter at any time, ie revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail.

Used services and service providers:

Web analysis, monitoring and optimization

The web analysis (also referred to as “range measurement”) is used to evaluate the flow of visitors to our online offer and can include behavior, interests or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of the range analysis, we can, for example, recognize at which time our online offer or its functions or content are used most often or invite you to reuse. We can also understand which areas need optimization.

In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offer or its components.

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

The IP addresses of the users are also saved. However, we use an IP masking process (ie pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A / B testing and optimization, no clear user data (such as e-mail addresses or names) are saved, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context we would like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest- / behavior-related profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Used services and service providers:

  • etracker: Web analysis / range measurement; Service provider: etracker GmbH, Erste Brunnenstrasse 1 20459 Hamburg, Germany; Website: https://www.etracker.com ; Data protection: https://www.etracker.com/datenschutz/ ; Opposition option (opt-out): https://www.etracker.de/privacy?et=[BITTE-EINSETZEN-IHRE-Account-ID] .
  • Matomo (without cookies): Matomo is data protection-friendly web analysis software that is used without cookies and with which recurring users are recognized with the help of a so-called “digital fingerprint”, which is stored anonymously and changed every 24 hours; With the “digital fingerprint”, user movements within our online offer are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that it is not possible to draw conclusions about the identity of individual users; Service provider: web analysis / range measurement in self-hosting; Website: https://matomo.org/ .

Online marketing

We process personal data for online marketing purposes, which can 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 their effectiveness.

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

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

The information in the profiles is usually stored in the cookies or by means of similar processes. These cookies can later generally also be read out on other websites that use the same online marketing process, analyzed for the purpose of displaying content and supplemented with additional data and stored on the server of the online marketing process provider.

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

In principle, we only have 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 processes have led to a so-called conversion, i.e., for example, to 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 the cookies used will be stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context we would like to draw your attention to the information on the use of cookies in this data protection declaration.

Facebook pixel : With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to only send the Facebook ads placed by us to those users on Facebook and within the services of the partners cooperating with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we would also like to ensure that our Facebook ads correspond to the potential interest of the users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advertisement (so-called “conversion measurement”).

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person).
  • Affected people: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest / behavior-related profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavior-related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of returning visitors), target group formation (Determination of target groups relevant for marketing purposes or other output of content), Cross-Device Tracking (cross-device processing of user data for marketing purposes).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opposition option (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection given to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, there is the option of switching off cookies in your browser settings. However, this can restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary 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-regional: https://optout.aboutads.info .

Used services and service providers:

  • Google Tag Manager: Google Tag Manager is a solution with which we manage so-called website tags via an interface and thus integrate other services into our online offer. The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Data protection: https://policies.google.com/privacy .
  • Google Analytics: Online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/ ; Data protection: https://policies.google.com/privacy ; Opposition option (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de , Settings for the display of advertisements: https://adssettings.google.com/authenticated .
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place advertisements in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they can be displayed to users who have a presumed interest in the advertisements. We also measure the conversion of the ads. However, we only find out the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we ourselves do not receive any information that can be used to identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Data protection: https://policies.google.com/privacy .
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place advertisements in the Google advertising network (eg, in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that advertisements are displayed in real time based on the presumed interests of the users. This allows us to display advertisements for and within our online offer in a more targeted manner in order to only present users with advertisements that potentially correspond to their interests. If, for example, a user is shown advertisements for products that he was interested in on other online offers, this is referred to as “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com ; Data protection: https://policies.google.com/privacy .
  • Facebook pixel: Service provider: https://www.facebook.com , Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com ; Data protection: https://www.facebook.com/about/privacy ; Opposition option (opt-out): https://www.facebook.com/settings?tab=ads .

Presence in social networks (social media)

We maintain an online presence 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 can be processed outside of the European Union. This can result in risks for the user because it could make it more difficult to enforce the rights of the user, for example.

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

For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), we 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 point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP Addresses).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact inquiries and communication, tracking (e.g. interest- / behavior-related profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Used services and service providers:

Plugins and embedded functions as well as content

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

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

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (ie interest in efficient, economical and recipient-friendly services). In this context we would like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta / communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact details (e.g. e-mail, telephone numbers).
  • Affected people: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g. interest / behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and answering inquiries.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit.f.GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR).

Used services and service providers:

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitted for processing is revoked or other permissions are no longer applicable (e.g. if the purpose of processing this data is no longer applicable or is not required for the purpose).

If the data are not deleted because they are required for other legally permissible purposes, their processing will be limited to these purposes. In other words, the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

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

Change and update of the data protection declaration

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

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

Rights of data subjects

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

  • Right of objection: You have the right, for reasons that arise from your particular situation, to object at any time to the processing of your personal data, which is based on Art. 6 Para. 1 lit. e or f GDPR takes place to object; this also applies to profiling based on these provisions. If the personal data relating to you are processed in order to operate direct mail, you have the right to object at any time to the processing of the personal data relating to you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.
  • Right to withdraw consent: You have the right to withdraw your consent at any time.
  • Right of providing information: You have the right to request confirmation as to whether the relevant data is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request the completion of the data relating to you or the correction of incorrect data relating to you.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request a restriction on the processing of the data in accordance with the legal requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
  • Complaint to the supervisory authority: You also have the right, in accordance with the legal requirements, to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged violation, if you are of the opinion that the processing of the personal data concerning you is contrary to GDPR violates.

Definitions of terms

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

  • Visit action evaluation: “Visit action evaluation” (English “Conversion Tracking”) describes a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can see whether the advertisements we placed on other websites were successful).
  • Credit Report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online loan application or an online application process without any human intervention. According to Art. 22 GDPR, such automated decisions are only permitted if the data subjects consent, if they are necessary for the performance of a contract or if national laws allow these decisions.
  • Cross-device tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning an online identifier to the users. As a result, the user information can usually be analyzed for marketing purposes regardless of the browser or device used (e.g. mobile phones or desktop computers). With most providers, the online identification is not linked to clear data such as names, postal addresses or e-mail addresses.
  • IP masking: “IP masking” is a method in which the last octet, ie the last two digits of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing methods, especially in online marketing
  • Interest-based and behavioral marketing: One speaks of interest-based and / or behavior-based marketing when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting certain websites and lingering on them, buying behavior or interaction with other users), which are stored in a so-called profile. Cookies are usually used for these purposes.
  • Conversion measurement: Conversion measurement is a method that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can see whether the advertisements we placed on other websites were successful.
  • Personal data: “Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is regarded as identifiable who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, which express the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
  • Profiling: “Profiling” is any type of automated processing of personal data that consists of using this personal data to identify certain personal aspects that relate to a natural person (depending on the type of profiling, this includes information on age, to analyze, evaluate or predict the gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people (e.g. the interests in certain content or products, the click behavior on a website or the whereabouts ). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: The range measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of the range analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This enables you to better adapt the content of the website to the needs of your visitors, for example. For the purpose of range analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus to receive more precise analyzes of the use of an online offer.
  • Remarketing: One speaks of “remarketing” or “retargeting” 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, for example in advertisements.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and functions of location determination. Location data are used to indicate the geographically determinable position on the earth at which the respective device is located. Location data can e.g. B. can be used to display map functions or other information dependent on a location.
  • Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information with regard to the online offers used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match their interests.
  • Responsible: “Responsible” is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term goes far and includes practically every handling of data, be it the collection, the evaluation, the storage, the transmission or the deletion.
  • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. showing 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 shop in which he viewed the products. One speaks of “lookalike audiences” (or similar target groups), in turn, when the content assessed as suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are usually used for the purpose of creating custom audiences and lookalike audiences.
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