This privacy statement clarifies the nature, scope and purpose of the processing of personal data (hereinafter “data”) in the context our services and related websites, functions and contents as well as external online services, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “responsible person”, we refer to the definitions in article 4 of the European Data Protection Act (GDPR).
Responsible Officer for data privacy
Data Protection Officer: Henry Upmeyer
Types of data processed
-Inventory data (e.g., identification, names or addresses).
-Contact information (e.g., e-mail, telephone numbers).
-Content data (e.g., text input, photographs, videos).
-usage data (e.g., visited websites, interest in content, access times).
-meta-/communication data (e.g., device information, IP addresses).
Categories of persons affected
Visitors and users of the online offer (hereinafter we refer to the persons concerned as “users”).
Purpose of processing
-Provision of the online offer, its functions and contents.
-Answering contact inquiries and communicating with users.
“Personal data” shall be any information relating to an identified or identifiable natural person (hereinafter referred to as “the person concerned”); A natural person is considered to be identifiable, either directly or indirectly, in particular by assigning an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics which can be used as an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term shall be interpreted broadly and covers virtually every use of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific person without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate or predict certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, preferences, personal interests, reliability, behavior, whereabouts or relocation of that natural person.
The “person responsible” shall mean the natural or legal entity, authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
“Processor” means any natural or legal person, public authority, body or body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with article 13 of the GDPR, we will inform you of the legal basis of our data processing. For users which are subject to the the European Data Protection Act (GDPR), i.e. the EU and the EEC, if the legal basis is not mentioned in the data Protection declaration, the following shall apply:
The legal basis for obtaining consent is Article 6, para, (1) lit. (a) and article 7 GDPR;
The legal basis for processing for the performance of our services and the implementation of contractual measures as well as answering inquiries is Article 6 para. (1) lit. (b) GDPR;
The legal basis for processing in order to comply with our legal obligations is Article 6 ( (1) lit. (c) GDPR;
In the event that vital interests of the person concerned or of another natural person require the processing of personal data, article 6 Para. (1) lit. (d) GDPR applies as a legal basis.
The legal basis for the necessary processing to carry out a task in the public interest or in the exercise of public authority transferred to the person responsible is Article 6 ( (1) lit. (e) GDPR.
The legal basis for processing in order to safeguard our legitimate interests is Article 6 ( (1) lit. f DSGVO (European Data Protection Act)
The processing of data for purposes other than those for which it was collected is subjet to the requirements of Art 6 (6). 4 GDPR.
The processing of special categories of data (in accordance with article 9 (1) GDPR) shall be governed by the requirements of article 9 para. 2 GDPR.
We meet the legal requirements taking into account up to date and state of the art IT systems, the implementation costs and the nature, scope, circumstances and purposes of processing, as well as the varying likelihood of occurrence and severity of the Risk for the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the satisfaction of the data subject’s rights, including data deletion and appropriate safety measures in case of increased data vulnerability. In addition, we take the protection of personal data into account in the development, or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly presets.
Working with contract processors, other jointly responsible- and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (eg if the data has been transmitted to third parties, such as payment service providers, to fulfill the contract), users have consented to a legal obligation to do so or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.).
Insofar as we disclose data to other companies in our group, convey it or otherwise grant access to it, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis that complies with the legal requirements.
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third party services or disclosure, or transmission of data to other persons or companies This will only happen if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to explicit consent or necessary contractual obligations to transmit data, we only process or leave the data in third countries with a recognised level of data protection, including US processors certified under the “Privacy Shield,” or on the basis of special guarantees, such as contractual obligation by so-called standard protection clauses of the EU Commission, or certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission).
Rights of data subjects
You have the right to ask for confirmation as to whether such data is being processed and for information about this data, as well as for further information and copy of the data in accordance with legal requirements.
You have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with the legal requirements, you have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.
You have the right to request that the data relating to you provided to us be obtained in accordance with the statutory requirements and to request their transmission to other persons responsible.
You also have the right, in accordance with the statutory provisions, to submit a complaint to the competent supervisory authority.
Right of Withdrawal
You have the right to revoke consents with effect for the future.
Right to Object
You may object to the future processing of the data concerning you at any time in accordance with the legal requirements. The objection may in particular be against processing for direct marketing purposes.
Cookies and right of objection to direct advertising
“Cookies” are small files that are stored on users ‘ computers. Within the cookies, different data can be stored. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. As temporary cookies, or “Session cookies” or “transient cookies”, cookies are called, which are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart can be stored in an online shop or a login status. “Permanent” or “persistent” are cookies that remain stored even after the browser is closed. For example, the login status can be saved if the users visit them after several days. Similarly, in such a cookie, the interests of users who are used for range measurement or marketing purposes can be stored. “Third-party-cookie” means cookies that are offered by other providers than the person in charge of the online offer (otherwise, if it is only their cookies, it is called “first-party Cookies”).
If users do not want cookies to be stored on their computer, they will be asked to disable the corresponding option in their browser’s system preferences. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in the scope of this data protection declaration, the data stored with us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with statutory retention obligations.
If the data is not deleted because it is necessary for other and legally permissible purposes, its processing will be restricted. i.e. the data is locked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
Users can create a user account. As part of the registration process, the required mandatory information is communicated to the users and based on article 6 para. (1) lit. b GDPR processed for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered as part of the registration will be used for the purpose of using the user account.
Users can be informed by e-mail about information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with respect to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data in the event of termination before the end of the contract. We are entitled to permanently delete all data stored by the user during the duration of the contract.
As part of the use of our registration and registration functions as well as the usage of the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data is not passed on to third parties in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 para. (1) lit. C. GDPR. The IP addresses will be anonymized or deleted at the latest after 7 days.
Comments and contributions
If users leave comments or other contributions, their IP addresses may , based on our legitimate interests within the meaning of article 6 para. (1) lit. F. GDPR be saved for 7 days. This is for our safety if someone leaves unlawful content in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we may be sued for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, in accordance with our legitimate interests. Art. 6 para. (1) lit. f. GDPR to process the information of users for the purpose of spam detection.
The information provided in the context of the comments and contributions to the person, any contact and website information as well as the content information, are permanently stored by us up to the opposition of the users.
Users can subscribe to the follow-up comments based on their consent according to Art. 6 para. (1) lit . Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from current comment subscriptions at any time. The confirmation email will contain information about the revocation options. For the purpose of obtaining the consent of the users, we save the registration time along with the IP address of the users and delete this information when users log off from the subscription.
You can cancel the receipt of our subscription at any time, i.e. Revoke your consent. We may store the e-mail addresses held for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of possible defence against claims. An individual cancellation request is possible at any time, if at the same time the former existence of a consent is confirmed.
Our online offering uses the “Akismet” service offered by Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the US, where it is analyzed and stored for four days for comparison. If a comment has been classified as spam, the data will be stored beyond that time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used, the computer system and the time of the entry.
More information on the collection and use of the data by Akismet can be found in the data protection notices of Automattic: https://automattic.com/privacy/.
Users are welcome to use pseudonyms, or to refrain from entering the name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a shame, but unfortunately we see no other alternatives that work equally effectively.
Retrieving emojis and Smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphic files that express feelings, are used, which are obtained from external servers. In this case, the providers of the servers collect the IP addresses of the users. This is necessary so that the Emojie files can be transmitted to the users ‘ browsers. The Emojie service is offered by Autolanguic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Autolanguic Privacy Notice: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, which in our knowledge is called Content-delivery-networks, i.e. servers which serve only for fast and secure transmission of the files and the personal data of the deleted by the user after transmission.
The use of the emojis takes place on the basis of our legitimate interests, i.e. interest in an attractive design of our online offer according to Art. 6 para. (1) lit. F. GDPR.
When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the user to process the contact request are processed acc. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization.
We will delete the requests if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security, and technical maintenance services we use to operate this online service.
Wevor our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. (1) lit. f GDPR together with Art. 28 GDPR (Conclusion of order processing contract).
Collection of Access data and logfiles
We, and our hosting provider, collects on the basis of our legitimate interests within the meaning of article 6 para. (1) lit. F. GDPR data about each access to the server on which this service resides (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
LogFile information is stored for a maximum of 7 days for security reasons (e.g. for the investigation of abuse or fraud actions) and then deleted. Data for which further storage is required for evidence is excluded from the deletion until the final clarification of the respective incident.
Google AdWords and Conversion measurement
We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, (“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We may use the Google AdWords Online marketing process to place ads on the Google advertising network (e.g., in search results, in videos, on Web pages, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to selectively display ads for and within our online offering to show users only ads that potentially correspond to their interests. For example, if a user is shown ads for products for which he or she is interested in other online offers, this is referred to as “remarketing”. For these purposes, when we call up our and other websites where the Google advertising network is active, Google will execute a code directly from Google, and so-called (re) marketing tags (invisible graphics or code, also known as “Web beacons”) on the website. With their help, the user is provided with an individual cookie on their device, that means a small file is saved (instead of cookies, comparable technologies can be used). This file is used to identify which web pages the user is interested in, for which content he or she has clicked and what offers the user has selected, as well as technical information about the browser and operating system, referring Web pages, visiting time and other Information on the use of the online offer.
We also receive an individual “conversion cookie”. The information obtained using the cookie is used by Google to create conversion statistics for us. However, we will only see the total number of anonymous users who clicked on our ad and were redirected to a conversion tracking tag page. We do not receive any information that allows users to identify themselves personally.
The user’s data is processed under the Google advertising network pseudonym. i.e. Google does not store and process the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That means that in Google’s perspective, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected through the users is sent to Google and stored in the United States on Google’s servers.
For more information on Google’s use of data, settings and objection, see Google’s Privacy Statement (https://policies.google.com/technologies/ads) and the settings for the presentation of Advertising by Google (https://adssettings.google.com/authenticated).
Jetpack (WordPress Stats)
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of art. 6 para. 1 lit. f. GDPR), we use the Jetpack plugin (here the subfunction “WordPress stats”), which is a tool for Statistical evaluation of visitor Access and by Autolanguic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files which are stored on your computer and which allow an analysis of the use of the website by you.
The information generated by the cookie about your use of this online offer is stored on a server in the USA. This allows users to create user profiles from the processed data, which are only used for analysis and not for advertising purposes. For more information, please see the privacy Statement of Autolanguic: https://automattic.com/privacy/ and notes about jetpack cookies: https://jetpack.com/support/cookies/.
Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.
We point out that data of the users outside the area of the European Union can be processed. This may result in risks for the users because e.g. enforcement of user rights could be made more difficult. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards.
Furthermore, the data of the users are usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from the user behavior and the resulting interests of the users. The usage profiles can in turn be used to e.g. Place advertisements inside and outside the platforms that are allegedly in line with users’ interests. For these purposes, cookies are usually stored on the computers of the users, in which the user behavior and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).
The processing of personal data of users is based on our legitimate interests in an effective information of users and communication with users in accordance with. Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers of the platforms for a consent to the above-described data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of contradiction (opt-out), we refer to the following linked information of the provider.
Also in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, then you can contact us.
– Facebook, -Pages, -Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) auf Grundlage einer Agreement on joint processing of personal data-Privacy Statement: https://www.facebook.com/about/privacy/, especially for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
-Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Statement/Opt-Out: http://instagram.com/about/legal/privacy/.
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Datenschutzerklärung: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
-Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Statement/Opt-Out: https://about.pinterest.com/de/privacy-policy.
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Datenschutzerklärung https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out,Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland) – Datenschutzerklärung/ Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung.
– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Datenschutzerklärung/ Opt-Out: https://wakelet.com/privacy.html.
– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Deutschland) – Datenschutzerklärung/ Opt-Out: https://soundcloud.com/pages/privacy.
Integration of services and contents of third parties
We place within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of art. 6 para. 1 lit. f. GDPR) content or service offers from Third-party providers to incorporate their content and services, such as videos or fonts (hereinafter referred to as “content”).
This always assumes that the third-party providers of this content perceive the IP address of the users, since they could not send the contents to their browsers without the IP address. Insofar, the IP-Adress is necessary for this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.
Using Facebook Social plugins
We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of article 6 para 1 lit. f. GDPR) Social plugins (“plugins”) of the social network facebook.com, which is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is operated (“Facebook”).
This may include, for example, content such as images, videos or texts and buttons, with which users can share the contents of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls a function of this online offer that contains such a plugin, his device establishes a direct connection with the servers of Facebook. The content of the plugin is transmitted directly by Facebook to the user’s device and is included in the online offer. Users profiles can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore inform users according to our knowledge level.
By incorporating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged on to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example press the Like button or leave a comment, the corresponding information is transmitted from their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will know and store its IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the rights and settings to protect the privacy of users in this regard, can be read in Facebook’s data protection notices: https://www.facebook.com/about/privacy/.
If a user is a user of Facebook and does not want Facebook to collect data about him via this online offer and link it with his member data stored on Facebook, he must log out before using our online offer on Facebook and his Delete Cookies. Further settings and objections regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ Or the EU side http://www.youronlinechoices.com/. The settings are platform independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Within our online offering, Twitter service features and content, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated. This may include, for example, content such as images, videos or texts and buttons that allow users to share content from this online offer within Twitter.
Within our online offering, Pinterest service features and content, offered by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA, can be used. This may include, for example, content such as images, videos or texts and buttons that allow users to share content from this online offer within Pinterest. If the users are members of the Pinterest platform, Pinterest can assign the call of the above content and functions to the profiles of the users. Pinterest Privacy Statement: https://about.pinterest.com/de/privacy-policy.