Introduction
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The 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, 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: 27 June 2021
Content overview
Introduction
Person responsible
Overview of processing operations
Relevant legal basis
Security measures
Transfer of personal data
Data processing in third countries
Use of cookies
Payment procedures
Provision of the online offer and web hosting
Contacting
Communication via messenger
Cloud services
Newsletter and electronic notifications
Promotional communication via e-mail, post, fax or telephone
Web analysis, monitoring and optimisation
Online marketing
Rating platforms
Plugins and embedded functions and content
Deletion of data
Amendment and updating of the privacy policy
Rights of data subjects
Definitions
Person responsible:
Algarveda n.e.V.
CP 410-M
8670-014 Aljezur
Portugal
Persons authorised to represent: Holger Brandt.
E-mail address: mail@algarveda.com.
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
Inventory data (e.g. names, addresses).
Content data (e.g. entries in online forms).
Contact data (e.g. e-mail, telephone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. websites visited, interest in content, access times).
Contract data (e.g. subject matter of contract, term, customer category).
Payment data (e.g. bank details, invoices, payment history).
Categories of data subjects
Employees (e.g. employees, applicants, former employees).
Interested parties.
Communication partners.
Customers.
Users (e.g. website visitors, users of online services).
Purposes of the processing
Provision of our online services and user friendliness.
Office and organisational procedures.
Direct marketing (e.g. by email or post).
Feedback (e.g. collecting feedback via online form).
Marketing.
Contact requests and communication.
Profiles with user-related information (creating user profiles).
Reach measurement (e.g. access statistics, recognition of returning visitors).
Provision of contractual services and customer service.
Relevant legal basis
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 be relevant in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
Security measures
We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of 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, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised 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 DSGVO, 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 visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his or her visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. where user details are stored using pseudonymous online identifiers, also known as “user IDs”).
The following cookie types and functions are distinguished:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
Permanent cookies: Permanent cookies remain stored 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. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.
First-party cookies: First-party cookies are set by ourselves.
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: Cookies may, on the one hand, be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
Statistical, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) are of particular importance.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the https://optout.aboutads.info and https://www.youronlinechoices.com/ websites. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is 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.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Payment procedure
In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively “payment service providers”).
The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Customers, interested parties.
Purposes of processing: provision of contractual services and customer service.
Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
Giropay: Payment services; Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Website: https://www.giropay.de; Privacy policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
Klarna / Sofortüberweisung: Payment services; Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Website: https://www.klarna.com/de; Privacy policy: https://www.klarna.com/de/datenschutz.
Mastercard: payment services; service provider: Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium; website: https://www.mastercard.de/de-de.html; privacy policy: https://www.mastercard.de/de-de/datenschutz.html.
PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com/de; privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Visa: payment services; service provider: Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, GB; Website: https://www.visa.de; Privacy Policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
Provision of the online offer and web hosting
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness.
Legal grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services used and service providers:
ALL-INKL: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: ALL-INKL.COM – Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Website: https://all-inkl.com/; Privacy policy: https://all-inkl.com/datenschutzinformationen/.
Contacting
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the inquiring person is processed to the extent necessary to respond to the contact requests and any measures requested.
The response to contact enquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
Data subjects: Communication partners.
Purposes of processing: contact requests and communication.
Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us in alternative ways, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of messengers with encryption enabled to ensure that the message content is encrypted.
Cloud services
We use software services accessible via the internet and running on their providers’ servers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Customers, employees (e.g. employees, applicants, former employees), prospective customers, communication partners.
Purposes of processing: Office and organisational procedures.
Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Newsletter and electronic notifications
We send newsletters, e-mails and other electronic notifications (hereinafter “newsletter”) only with the consent of the recipients or with a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.
Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Notes on legal basis: The newsletter is sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
Measurement of opening and click-through rates:
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is sent to the recipient when the newsletter is opened.
Measurement of opening and click-through 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. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened and when they are opened.
Prerequisite for the use of free services: Consent to the sending of mailings may be made conditional as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
Data subjects: Communication partners, users (e.g. website visitors, users of online services).
Purposes of processing: direct marketing (e.g. by email or post), provision of contractual services and customer service.
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Opt-out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.
Services used and service providers:
Mailchimp: email delivery and email marketing platform; service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; privacy policy: https://mailchimp.com/legal/privacy/; standard contractual clauses as the basis for processing in the USA: https://mailchimp.com/legal/data-processing-addendum/; special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Promotional communication via email, post, fax or telephone
We process personal data for the purposes of promotional communications, which may take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.
After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
Data subjects: Communication partners.
Purposes of processing: direct marketing (e.g. by e-mail or post).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Web analysis, monitoring and optimisation
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation 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 optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.
Notes on legal basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), profiles with user-related information (creation of user profiles).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Online marketing
We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information about the user relevant to 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. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network.
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of promotional and other content (collectively, “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 information about the user relevant to 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. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored within the scope of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the users’ profiles with the aforementioned data. We ask you to note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal basis: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: marketing, profiling with user-related information (creating user profiles).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the possibilities of objection given to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional 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-territory: https://optout.aboutads.info.
Services used and service providers:
Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offer (please refer to further information in this data protection declaration). The Tag Manager itself (which implements the tags) does not create user profiles or store cookies. Google only learns the user’s IP address, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; privacy policy: https://policies.google.com/privacy.
Google Analytics: Online marketing and web analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for display of ads: https://adssettings.google.com/authenticated.
Rating platforms
We participate in rating procedures in order to evaluate, optimise and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers.
In order to ensure that the persons rating have actually used our services, we transmit, with the consent of the customers, the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.
Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) which are necessary so that the content of the widget can be delivered to the user’s browser.
Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online services participating 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.
Types of data processed: contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Data subjects: Customers, users (e.g. website visitors, users of online services).
Purposes of processing: feedback (e.g. collecting feedback via online form), marketing.
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Plugins and embedded functions and content
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can 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 without the IP address they would not be able to send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour 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. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
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 customer service, profiles with user-related information (creation of user profiles).
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).
Services used and service providers:
Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy.
YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad display settings: https://adssettings.google.com/authenticated.
Vimeo: Video content; Service provider: Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Opt-out: We would like to point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Our data protection notices may also contain further information on the retention and deletion of data, which will take precedence for the respective processing operations.
Modification and updating of the data protection notice
We ask you to regularly check the content of our data protection notice. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.
Rights of data subjects
As a data subject, you have various rights under the GDPR, in particular as set out in Articles 15 to 21 of the GDPR:
Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to revoke any consent given at any time.
Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
Complaint to a supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing.
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 such personal data to analyse, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour 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 visitors’ behaviour or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
Controller: “Controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.