Preface
With the following data protection declaration, we would like to inform you about which of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. This 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 devices, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender specific.
Cologne, December 08.04.2024, XNUMX
Overview of the content
- Preface
- responsible person
- Overview of processing
- Contact the data protection officer
- Relevant legal bases
- Security Measures:
- transmission and disclosure of personal data
- Data processing in third countries
- Use of Cookies
- Commercial and business services
- payment service providers
- Credit check
- provision of online services and web hosting
- Contact
- newsletters and electronic notifications
- Web analysis, monitoring and optimization
- online marketing
- presence in social networks (social media)
- Plugins and embedded functions and content
- Deletion of data
- Changes and updates to the privacy policy
- Rights of data subjects
- definitions of terms
responsible person
Managing Director
Ernst Jan Rolloos / White Label Pharma GmbH
Hohenzollernring 38-40, 50672 Cologne
Germany
E-mail address: info@white-label-pharma.eu
Phone: +49 171 8162418
Contact the data protection officer
Miriam Gueth / White Label Pharma GmbH
Hohenzollernring 38-40, 50672 Cologne, Germany
Overview of processing
The following overview provides an overview of the types of data processed and the purposes of their processing and refers to the persons concerned.
Types of processed data
- Inventory data (e.g. names, addresses).
- Content data (e.g. entries in online forms).
- Contact information (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 about the geographic location of a device or person).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
categories of data subjects
- Business and contractor.
- Interested parties.
- Communication partner.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of Processing
- Assessment of creditworthiness and creditworthiness.
- Providing our online services and user experience.
- Evaluation of the visit campaign.
- office and organizational processes.
- 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 (creating user profiles).
- remarketing.
- Reach measurement (e.g. access statistics, recognition of returning visitors).
- Safety measures.
- Tracking (e.g. interest/behavioral profiling, use of cookies).
- Provision of contractual services and customer service.
- Management and answering of inquiries.
- Targeting (identifying audiences relevant for marketing purposes or other content output).
Automated decisions on a case-by-case basis
- Credit information (decision based on a credit check).
Relevant legal bases
Below we inform you of the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations 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 his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
- Contractual performance and pre-contractual measures (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Security Measures:
Taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihoods of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures in accordance with the legal provisions to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of the data by controlling physical and electronic access to the data as well as access, input, transmission, ensuring availability and separation. In addition, we have established procedures to ensure the exercise of the rights of the data subjects, the deletion of data and the response to data compromises. In addition, we take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): We use SSL encryption to protect the data you transmit via our website. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
transmission and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may be, 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 these cases, we adhere to the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data processing in third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only take place in accordance with the statutory provisions.
Subject to express consent or contractual or legal transmission obligations, we process the data or have it transferred only in third countries with a recognized level of data protection, contractual binding 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 ).
As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure as part of the adequacy decision of July 10, 2023. The list of certified companies and further information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we inform you which service providers we use are certified according to the Data Privacy Framework.
Use of Cookies
Cookies are small text files or other storage tags that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online service. Cookies can also be used for various purposes, e.g. for the purposes of functionality, security and convenience of online services and to create analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal provisions. We therefore obtain the prior consent of users unless this is not required by law. Consent is not required in particular if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (ie our online offering). The revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Notes on data protection legal bases: The data protection basis on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in operating our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which we process cookies in this data protection declaration or in our consent and processing procedures.
Duration of storage: With regard to the storage period, the following types of cookies are distinguished:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile app).
- Permanent Cookies:Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we explicitly inform users about the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data using cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection via the settings of your browser, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be made via a number of services, particularly in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained . In addition, you can obtain further instructions on your right to object as part of the information on the service providers and cookies used.
Processing of cookie data based on consent: We use a cookie consent management process within which users’ consent to the use of cookies or to the processing and providers named in the cookie consent management process is obtained and managed, and can be revoked by users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. The data can be saved on the server and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The consent can be saved for up to two years. A pseudonymous user ID is created and, along with the time of consent, information about the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and device used is saved.
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") within the framework of contractual and comparable legal relationships as well as related measures and within the framework of communication with contractual partners (or pre-contractually), e.g. to answer inquiries.
We process this data to fulfill our contractual obligations, to protect our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only pass on data from contractual partners to third parties if this is necessary for the aforementioned purposes or to fulfill legal obligations or if the data subjects have consented (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners are informed about other forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar) or personally, which data is required for the aforementioned purposes.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. usually after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes, usually 10 years). We delete the data provided to us by the contractual partner as part of an order in accordance with the specifications of the order, usually after completion of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Account: Contractual partners can create an account within our online offering (e.g. customer or user account, in short "customer account"). If registration of a customer account is required, the contractual partners will be informed of this and of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. During registration and the subsequent login and use of the customer account, we store the customers' IP addresses together with the access times in order to be able to prove registration and prevent misuse of the customer account.
When customers have terminated their customer account, the data associated with the customer account will be deleted unless its retention is required for legal reasons. It is the customers' responsibility to back up their data when their customer account is terminated.
economic analysis and market research: For business reasons and in order to be able to identify market trends and the wishes of contractual partners and users, we evaluate the data available to us on business transactions, contracts, inquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offering may be among the persons affected.
The analyses are carried out for the purposes of company evaluation, marketing and market research (e.g. to identify customer groups with different characteristics). In doing so, we can take into account the profiles of registered users with their information, e.g. on the services used, if available. The analyses are for our sole use and are not passed on to third parties, unless they are anonymous analyses with summarized, i.e. anonymized values. In addition, we take the privacy of users into account and process the data for analysis purposes as pseudonymously as possible and, if possible, anonymously (e.g. as summarized data).
Shop and e-commerce: We process our customers' data to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for and deliver or execute them. To the extent necessary to execute an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery or execution to our customers. We use the services of banks and payment service providers to process payment transactions. The required information is marked as such in the ordering or similar procurement process and includes the information required for delivery or provision and billing, as well as contact information so that any consultation can take place.
- Types of processed data: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment behavior), contact data (e.g. e-mail, telephone numbers), contract data, 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 requests and communication, office and organizational processes, administration and response to inquiries, security measures, evaluation of visits, interest-based and behavioral marketing, profiling (creation of user profiles).
- Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
payment service
Within the framework 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 for this purpose we use other payment service providers (collectively "payment service providers") in addition to banks and credit institutions.
The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications, apply to payment transactions. We also refer to these for the purpose of further information and the assertion of revocation, information and other rights of those affected.
- Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment behavior), 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: Customers, potential customers.
- Purposes of processing: Provision of contractual services and customer service.
- Legal basis: Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services used and service providers:
- PayPal: Payment services and solutions (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 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.
Credit check
Insofar as we make advance payments or take comparable economic risks (e.g. when ordering on account), we reserve the right, in order to safeguard our legitimate interests, to obtain identity and creditworthiness information from specialised service providers (credit agencies) for the purpose of assessing the credit risk on the basis of mathematical and statistical procedures.
We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or other advance payments in the event of a negative result of the credit check.
In accordance with Art. 22 GDPR, the decision as to whether we provide advance services is made exclusively on the basis of an automated decision in the individual case, which is made by our software on the basis of the 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 given, the credit report is issued on the basis of our legitimate interests in securing our payment claims.
- Types of processed data: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, term, 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 individual decisions: Credit information (decision based on a credit check).
Services used and service providers:
provision of online services and web hosting
In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering 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 as part of the provision of the hosting service can include all information about the users of our online service that arises in the course of use and communication. This usually includes the IP address, which is necessary in order to be able to deliver the content of online services to browsers, and all entries that are made within our online service or from websites.
E-mail delivery and hosting: The web hosting services we use also include the sending, receiving and storing of emails. For these purposes, the addresses of the recipients and senders as well as other information about the email sending (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that emails are usually not transmitted encrypted on the Internet. Emails are usually encrypted during transport, but (unless so-called end-to-end encryption 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 emails between the sender and the reception on our server.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data about every access to the server (so-called server log files). The server log files can store 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 usually IP addresses as well as the requesting provider.
The server log files can be used for security purposes, e.g. to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
- Types of processed data: 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: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Contact
When you contact us (e.g. via contact form, email, telephone or social media), the data of the person making the inquiry will be processed to the extent necessary to answer the contact request and the desired action.
Contact requests within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre-)contractual requests and otherwise on the basis of legitimate interests in answering the requests.
- Types of processed data: 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: communication partners, interested parties.
- Purpose of processing: Contact inquiries and communication, management and answering inquiries.
- Legal basis: Contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Services used and service providers:
- contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data within the framework of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests and the interests of the communication partners in answering the requests and our statutory retention periods.
- Help Scout: Management of contact requests and messages; Service provider: Help Scout Inc, 131 Tremont St, Boston, MA 02111-1338, USA; Website: https://www.helpscout.net; Data protection statement: https://www.helpscout.net/company/legal/privacy/; Basis for third country transfer: standard contractual clauses(https://www.helpscout.com/company/legal/dpa/); Order processing contract: https://www.helpscout.com/company/legal/dpa/.
Electronic notifications
We only send emails and other electronic notifications with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for it, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is usually sufficient to provide your email address. However, we may ask you to provide a name in order to address you personally in the newsletter or to provide further information if this is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter is always done using a so-called double opt-in process. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Deletion and limitation of processing: Based on our legitimate interests, we may store the unsubscribed email addresses for up to three years before deleting them in order to be able to prove that consent was previously granted. 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 previous existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address in a blacklist for this purpose alone.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it was carried out correctly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure shipping process.
Notes on the legal basis: Newsletters are sent based on the consent of the recipients 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 emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.
Content: Information about us, our services, promotions and offers.
analysis and performance measurement: 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 shipping service provider, from its server. When this is retrieved, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected.
This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the shipping service provider to observe individual users. Rather, the evaluations help us to recognize the reading habits of our users and to tailor our content accordingly or to send other content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or an objection must be raised.
- Types of processed data: 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).
- Objection (opt-out): You can unsubscribe from our newsletter at any time, i.e. revoke your consent, or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options mentioned above, preferably email, for this purpose.
Services used and service providers:
- CleverReach: E-mail marketing platform; service provider: CleverReach GmbH & Co. KG, //CRASH building, Schafjückenweg 2, 26180 Rastede, Germany; website: https://www.cleverreach.com/de; Data protection statement: https://www.cleverreach.com/de/datenschutz/; Contract for order processing: concluded with provider.
- Mailchimp: Platform for email sending and email marketing; Service provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; Website: https://mailchimp.com; Data protection statement: https://mailchimp.com/legal/; Order processing contract: https://mailchimp.com/legal/; Basis for third country transfers: Data Privacy Framework, standard contractual clauses (included in the data processing agreement); Further information: Special security measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/.
Web analysis, monitoring and optimization
Web analysis (also known as "reach measurement") is used to evaluate visitor flows on our online offering and can contain behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, identify at what time our online offering or its functions or content are most frequently used or invite reuse. We can also identify in which areas there is a need for optimization.
In addition to web analysis, we can also use testing procedures, for example to test and optimize different versions of our online offering or its components.
For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie"), or similar procedures may be used for the same purpose. This information includes, for example, the content viewed, the websites visited and the elements used there, as well as technical information such as the browser used, the computer system used and information about the times of use. If users have consented to the collection of their location data, this may also be processed depending on the provider.
The IP addresses of users are also recorded. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, no unique user data (such as email addresses or names) is stored as part of web analyses, A/B tests and optimizations, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, only the information stored in their profiles for the purposes of the respective processes.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing the data is consent. Otherwise, the processing of user data is based on our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of processed data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-based profiling, use of cookies), evaluation of visit actions, 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).
Services used and service providers:
- etracker: Web analytics/reach measurement; service provider: etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, Germany; website: https://www.etracker.com; Data protection statement: https://www.etracker.com/datenschutz/; Order processing contract: https://www.etracker.com/av-vertrag/.
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to a device in order to recognize which content users have accessed within one or more usage processes, which search terms they have used, accessed again or interacted with our online offering. The time of use and its duration are also stored, as well as the sources of users who refer to our online offering and technical aspects of their devices and browsers. Pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. Analytics provides higher-level geographic location data by collecting the following metadata based on the IP search: "City" (and the derived latitude and longitude of the city), "Continent", "Country", "Region", "Subcontinent" (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users' IP addresses are not logged and are shortened by default by the last two digits. The IP address is shortened on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Contract for order processing: https://business.safety.google/adsprocessorterms/; Basis for transfers to third countries: Data Privacy Framework, standard contractual clauses(https://business.safety.google/adsprocessorterms); Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for displaying ads: https://adssettings.google.com/authenticated; More information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
- Google Tag Manager: Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offering (see also the further explanations in this privacy policy). The Tag Manager itself (which implements the tags) does not, for example, create user profiles or store cookies. Google only learns the user's IP address, which is required to operate 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; Agreement on order processing:
https://business.safety.google/adsprocessorterms; Basis for transfers to third countries: Data Privacy Framework, standard contractual clauses(https://business.safety.google/adsprocessorterms); Additional Information: https://privacy.google.com/businesses/adsservices (Types of processing and data processed).
online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively, “Content”) based on potential user interests and measuring their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used to store the information about the user relevant to the presentation of the aforementioned content. This information includes, for example, the content viewed, the websites visited, the online networks used, but also communication partners and technical information such as the browser used, the computer system used and information about the times of use. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also recorded. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no unique user data (such as email addresses or names) is stored in the context of online marketing, but pseudonyms. This means that we and the providers of the online marketing procedures 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 cookies or with the help of similar processes. These cookies can usually be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content, supplemented with further data and stored on the server of the provider of the online marketing process.
In exceptional cases, unique data can also be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing processes we use and the network links the users' profiles with the aforementioned data. We would like to point out that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, for example to the conclusion of a contract with us. The conversion measurement is used exclusively to analyze the success of our marketing measures.
Unless otherwise stated, please 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 use third-party providers, the legal basis for processing the data is consent. Otherwise, the processing of user data is based on our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of processed data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical location of a device or person).
- Affected people: Users (e.g. website visitors, users of online services), interested parties.
- Purposes of processing: Tracking (e.g. interest/behavior profiling, use of cookies), remarketing, evaluation of visit actions, interest and behavior-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), 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).
- Objection (opt-out): We refer to the data protection information of the respective providers and the options for objecting to the processing (so-called "opt-out"). If no explicit opt-out option has been specified, you can deactivate cookies in your browser settings. However, this can lead to functional restrictions on our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu.
Services used and service providers:
- Facebook pixels and target group formation (Custom Audiences): With the help of the Facebook pixel (or comparable functions for transmitting event data or contact information via interfaces in apps), Facebook is able to identify visitors to our online offering as a target group for placing advertisements (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook advertisements we place only to users on Facebook and within the services of partners who cooperate with Facebook (so-called “Audience Network”). https://www.facebook.com/audiencenetwork/ ) who have also shown interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interests of users and do not appear annoying. With the help of the Facebook pixel, we can track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for transfers to third countries: Data Privacy Framework, Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum) In the case of order processing by Facebook, this serves as the basis for the processing of event data from EU citizens in the USA and for inclusion in the “Facebook Platform Terms of Use” (https://developers.facebook.com/terms) with regard to Facebook's own processing of event data in the context of advertising; For more information: "General Terms and Conditions for Data Processing" (https://www.facebook.com/legal/terms/dataprocessing/update) apply to event data that Facebook processes on its behalf to provide companies with reports and analyses; in addition, the "Controller Addendum" applies as an agreement on joint responsibility (Art. 26 Para. 1 Clause 3 GDPR), which is relevant in the case of autonomous processing of event data by Facebook for the purposes of targeting, improving and securing Facebook's products.
- Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to display ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. In this way, we can display ads for and within our online offering in a more targeted manner in order to only present users with ads that may correspond to their interests. If a user is shown advertisements for products in which they were interested on other online offerings, for example, this is referred to as “remarketing”; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Data processing terms for Google advertising products: Information about the services Data processing terms between the controllers: https://business.safety.google/adscontrollerterms; when Google acts as a processor, data processing conditions for Google advertising products and standard contractual clauses for the transfer of data to third countries: https://business.safety.google/adsprocessorterms; Basis for transfer to third countries: data protection framework, standard contractual clauses(https://business.safety.google/adsprocessorterms).
- Google Ads and conversion measurement: We use the online marketing method “Google Ads” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are shown to users who are suspected of being interested in the ads (so-called “conversion”). We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called “conversion tracking tag”. However, we ourselves do not receive any information with which the users can be identified; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing and data processed: https://privacy.google.com/businesses/adsservices; Google Advertising Products Data Processing Terms: Information about services Data processing terms between controllers: https://business.safety.google/adscontrollerterms; Basis for third country transfers: data protection framework, standard contractual clauses(https://business.safety.google/adsprocessorterms).
presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users, as it may, for example, become more difficult to enforce users' rights.
In addition, user data in social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the user's usage behavior and the resulting interests. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the user's interests. For these purposes, cookies are usually stored on the user's computers in which the user's usage behavior and interests are stored. In addition, device-independent user data can also be stored in the user profiles (especially if the users are members of the respective platforms and are logged in there).
For a detailed description of the respective processing methods and the options for objection (opt-out), please refer to the data protection declarations and information provided by the operators of the respective networks.
We would also like to point out that requests for information and the assertion of data subject rights can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Types of processed data: 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: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavior profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services used and service providers:
- Facebook Pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they perform (see "Things you and others do and provide" in the Facebook data guidelines: https://www. facebook.com/policy) and information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook data policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services to page operators called "Page Insights" that help them understand how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information"). https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must comply with and in which Facebook has committed itself to fulfilling the rights of those affected (ie users can, for example, provide information or submit deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Page Insights Information" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service Provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; website:https://www.facebook.com; Privacy Policy:https://www.facebook.com/about/privacy; Basis for transfers to third countries: Data Privacy Framework, standard contractual clauses(https://www.facebook.com/legal/EU_data_transfer_addendum); Other information: Agreement on joint accountability:https://www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for transfer to a third country: standard contractual clauses(https://legal.linkedin.com/dpa). Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out; Order processing contract: https://legal.linkedin.com/dpa.
- YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Privacy policy: https://policies.google.com/privacy; Opt-out option: https://adssettings.google.com/authenticated; Basis for transfer to third countries: Data Privacy Framework.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Data protection statement: https://privacy.xing.com/de/datenschutzerklaerung.
Plugins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of the respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter referred to uniformly as "content").
The integration always requires that the third-party providers of this content process the user's IP address, since without the IP address they cannot send the content to their browser. The IP address is therefore required to display 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 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 analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, among other things, technical information about the browser and operating system, referring websites, the time of the visit and other information about the use of our online offering, as well as be linked to such information from other sources.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing the data is consent. Otherwise, the processing of user data is based on our legitimate interests (i.e. interest in efficient, economical and user-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Types of processed data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (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 offering and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavior-oriented marketing, profiling (creation of user profiles), security measures, administration and response to inquiries.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), contract performance and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).
Services used and service providers:
- Facebook plugins and content: Facebook social plugins and content – This can include content such as images, videos or texts and buttons that allow users to share content from this online offering within Facebook. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook. com/docs/plugins/ – We are jointly responsible with Meta Platforms Ireland Limited for collecting or receiving (but not for further processing) “Event Data” that Facebook collects or receives in the course of a transmission using the Facebook Social Plugins (and content embedding features) running on our online service, for the purposes of: a) displaying content and advertising information relevant to users’ presumed interests; b) delivering advertising and transactional messages (e.g. targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g. better identifying which content or advertising information is likely to match users’ interests). We have entered into a specific agreement with Facebook (“Responsible Party Addendum”). https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to respect the rights of the data subjects (i.e., users can, for example, provide information or submit deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not contain any information about individual users and are anonymous to us), this processing is not carried out under joint responsibility, but under a data processing agreement (“Data Processing Terms”), https://www.facebook.com/legal/terms/dataprocessing), the “Privacy Policy” (https://www.facebook.com/legal/terms/data_security_terms), and with regard to processing in the USA on the basis of standard contractual clauses (“Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
- Google Fonts: We integrate the fonts (“Google Fonts”) of the provider Google, whereby the user data is used exclusively 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 any licensing restrictions for their integration; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy.
- Google Maps: We integrate the maps of the “Google Maps” service provided by Google. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually as part of the settings of their mobile devices); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying ads: https://adssettings.google.com/authenticated.
- reCAPTCHA: We integrate the “reCAPTCHA” function to be able to recognize whether entries (e.g. in online forms) are made by people and not by automatically acting machines (so-called “bots”). The data processed may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keystrokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies and results of manual recognition processes (e.g. answering questions asked or selecting objects in images); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy Policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying ads: https://adssettings.google.com/authenticated.
- 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; Settings for displaying ads: 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: Please note that Vimeo may use Google Analytics and refer to its privacy policy(https://policies.google.com/privacy) and the opt-out options for Google Analytics(Https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data usage for marketing purposes(https://adssettings.google.com/).
Deletion of data
The data we process will be deleted in accordance with the statutory provisions as soon as your consent for processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data has ceased to exist or it is no longer required for the purpose).
If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary 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 be provided in the individual data protection notices of this Privacy Policy.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our data protection policy. We will adapt the privacy policy as soon as changes in the data processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another individual notification.
When we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please review the information before contacting us.
Rights of data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
- Right to: You have the right to object at any time to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
- Right to withdraw consent: You have the right to revoke your consent at any time.
- Right to information: You have the right to request confirmation as to whether the data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal provisions.
- Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data be corrected.
- Right to cancellation and limitation of processing: In accordance with the statutory provisions, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive the data concerning you that you have made available to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another responsible party.
- Complaint to a supervisory authority: You also 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, in accordance with the statutory provisions, if you consider that the processing of personal data concerning you infringes the GDPR.
definitions of terms
This section gives you an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand. The terms are listed alphabetically.
- Visit Action Evaluation: “Visit Action Evaluation” (or “conversion tracking”) is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device on the websites on which the marketing measures take place and then retrieved on the target website. This allows us to determine, for example, whether the ads we have placed on other websites were successful.
- Credit information: Automated decisions are based on automatic data processing without human intervention (e.g. automatic rejection of a purchase on account, an online credit application or an online application process without human intervention). Such automated decisions are only permissible under Art. 22 GDPR if the data subjects consent, if they are necessary for the performance of a contract or if national law allows such decisions.
- Cross-device tracking: Cross-device tracking is a form of tracking that collects user behavior and interest information across devices in so-called profiles by assigning users an online identifier. This enables user information to be analyzed for marketing purposes, regardless of the browsers or devices used (e.g. mobile phones or desktop computers). For most providers, the online identifier is not linked to unique data such as names, postal addresses or email addresses.
- IP masking: “IP masking” is a method that deletes the last octet, i.e. the last two digits of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing.
- Interest-based and behavioral marketing: Interest-based and/or behavior-oriented marketing is when the potential interests of users in advertisements and other content are predicted as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting certain websites and remaining on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
- Conversion measurement: Conversion measurement is a method of measuring the effectiveness of marketing efforts. To do this, a cookie is usually stored on users' devices on the websites where the marketing efforts take place and then retrieved on the target website. This allows us to determine, for example, whether the ads we have placed on other websites have been successful.
- Personal data: "Personal data" refers to any information relating to an identified or identifiable natural person (hereinafter referred to as the 'data subject'); an identifiable natural person is one who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or one or more specific factors expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (e.g. interest in certain content or use of certain services) (depending on the type of profiling, this may include information on age, gender, location data and movement data, interaction with websites and their content, purchasing behaviour, social interactions with other people), e.g. interest in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling.
- Audience measurement: Reach measurement (also known as web analysis) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, e.g. the content of web pages. With the help of reach analysis, website owners can, for example, see at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
- Remarketing: The term “remarketing” or “retargeting” refers to the process of recording, for example for advertising purposes, which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Location data: Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical intermediaries and location determination functions. Location data indicates the geographically definable position on earth where the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.
- Tracking: “Tracking” is when the behavior of users can be tracked across multiple online offerings. As a rule, behavior and interest information relating to the online offerings used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to show users advertising that may correspond to their interests.
- Responsible: A “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broadly defined and covers virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
- Audience Education: Target group formation (or "custom audiences") is when target groups are defined for advertising purposes, e.g. for placing advertisements. For example, a user's interest in certain products or topics on the Internet can be used to conclude that this user is interested in advertising for similar products or in the online shop in which he or she viewed the products. "Lookalike audiences" (or similar target groups) are used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to those of the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.