With the following data protection declaration we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online service”).
The terms used are not gender-specific.
Status: 4. October 2019
Content overview
- Introduction
- Responsible person
- Overview of processing operations
- Relevant legal bases
- Safety measures
- Transmission and disclosure of personal data
- Data processing in third countries
- Use of Cookies
- Registration and Login
- Blogs and Publication Media
- Contact us
- Provision of online services and web hosting
- Newsletter and wide communication
- Online marketing
- Presence in social networks
- Plugins and embedded functions as well as content
- Deletion of data
- Change and update of privacy policy
- Rights of the data subjects
- Definitions of terms
Responsible person
Kristin Werner
Weserstraße 37
12045 Berlin
E-Mail-address: hello@thephdlab.com
Overview of processing operations
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- Bestatus data (e.g. names, addresses).
- Content data (e.g. text input, photographs, videos).
- Contact data (e.g. e-mail, phone numbers).
- Meta/communication data (e.g.B. Device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
Categories of affected persons
- Interested parties.
- Communication partners.
- Users (e.g. website visitors, users of online services).
Purposes of processing
- Provision of our online services and user friendliness.
- Visit Promotion Evaluation.
- p>Direct Marketing (e.g. by e-mail or post).
- Feedback (e.g. collecting feedback via online form).
- Interest-based and behavioural marketing.
- Contact requests and communication.
- Conversion measurement (measurement of the effectiveness of marketing measures).
- Profiling (creation of user profiles).
- p>Remarketing.
- Range measurement (e.g. access statistics, recognition of returning visitors).
- Security measures.
- Tracking (e.g. interest/behavioral profiling, use of cookies).
- Contractual services and service.
- Administration and response to inquiries.
Applicable legal bases
In the following we inform you about the legal basis of the data protection basic regulation (DSGVO), on the basis of which we process personal data. Please note that, in addition to the provisions of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply.
- A Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO) – The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.
- Fulfilment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. a DSGVO) – The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes.
- Fulfilment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. a DSGVO) – The data subject has given his/her consent to the processing of his/her personal data for one or more specific purposes. 6 para. 1 sentence 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject.
- Protection of vital interests (Art. 6 para. 1 p. 1 lit. d. DSGVO) – Processing is necessary to protect vital interests of the data subject or another natural person.
- Goodful interests (Art. 6 para. 1 p. 1 lit. 1 DSGVO) – Processing is necessary to protect vital interests of the data subject or another natural person.
National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations apply to data protection in Germany. This includes, in particular, the German Data Protection Act (Bundesdatenschutzgesetz – BDSG). In particular, the BDSG contains special provisions on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may be applied.
Security measures
We shall take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, extent, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.
Actions shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, dissemination, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and responses to data breaches. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
SSL encryption (https): In order to protect your data transmitted via our online service, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission and disclosure of personal data
In the context of our processing of personal data, it may happen that the data is transferred to other offices, companies, legally independent organizational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions within the framework of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website.
Transmission and disclosure of personal data
In the context of our processing of personal data, it may happen that the data is transferred to other offices, companies, legally independent organizational units or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the framework of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and in particular conclude corresponding contracts or agreements with the recipients of your data which 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 the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Without express consent or transfer required by contract or law, we will only process or have the data processed 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 through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of Cookies
“Cookies” are small files that are stored on user devices. Cookies can be used to store different information. This information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed.
Cookies are usually also used when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., if user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
If we use cookies or tracking technologies, we will inform you separately in our privacy policy.
Information on legal bases: The legal basis on which we process your personal data with the aid of cookies depends on whether we ask you for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
General information on revocation and objection (opt-out): Irrespective of whether processing is based on consent or legal permission, you have the possibility at any time to revoke a consent given or to object to the processing of your data using cookie technologies (collectively referred to as “opt-out”).
You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online offering).
An objection to the use of cookies for online marketing purposes may also be raised through a variety of services, particularly in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info.
- >Processed data types: Usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g.B. Website visitors, users of online services).
- Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Registration and Login
users can create a user account. During the registration process, users are provided with the required mandatory information and processed for the purpose of providing the user account on the basis of contractual fulfilment of obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
The users can be informed by e-mail about processes that are relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
When using our registration and login functions as well as 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 those of the users in a protection against misuse and other unauthorized use. These data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Online-Forum: Participation in the forum requires a registration, which, unless otherwise stated in the registration form, requires one or your name, password and e-mail address to which the access data will be sent. For security reasons, the password should be state of the art, i.e. complicated (users will be notified of this during registration if necessary) and should not be used elsewhere. Contributions in the forum are visible to the public, unless their visibility is limited to certain members or groups of members. The contributions of the authors are stored with their names, if registered or indicated, the time and the entry contents. In the case of registrations and the creation of entries, the IP addresses of the users are also stored if the entries have an inadmissible content and the IP addresses could serve the prosecution. The person responsible reserves the right to delete the registrations and entries on the basis of an appropriate consideration.
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. Device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
- Persons affected: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Contractual achievements and service, safety measures, administration and answer of inquiries.
- Legal bases: Consent (Art. 6 Abs. 1 S. 1 lit. a DSGVO), contract fulfilment and pre-contractual inquiries (Art. 6 Abs. 1 S. 1 lit. b DSGVO), entitled interests (Art. 6 Abs. 1 S. 1 lit. f. DSGVO).
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer you to the information on the processing of visitors to our publication medium within the framework of this data protection notice.
Comments and posts: If users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security, if someone leaves illegal contents (insults, forbidden political propaganda etc.) in comments and contributions. In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
We also reserve the right, on the basis of our legitimate interests, to process user information for the purpose of spam detection.
On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies in order to avoid multiple voting.
The personal information provided in the course of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.
Akismet Anti-Spam Check: We use the “Akismet” service based on our legitimate interests. With the help of Akismet, comments from real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information about the browser used, the computer system and the time of the entry.
users are welcome to use pseudonyms or dispense with entering their name or email address. They can completely prevent the transmission of data by not using our comment system. That would be a shame, but unfortunately we do not see any alternatives that work just as effectively.
Profile pictures of Gravatar: We use the service Gravatar within our online offer and in particular in our blog.
Gravatar is a service where users can register and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile is stored for it. This is the sole purpose of transmitting the e-mail address. It will not be used for other purposes, but will be deleted afterwards.
The use of Gravatar is based on our legitimate interests, as we use Gravatar to offer contribution and comment writers the opportunity to personalize their contributions with a profile picture.
By displaying the images, Gravatar knows the IP address of the user, as this is necessary for communication between a browser and an online service.
If users do not want a user image linked to their e-mail address to appear in the comments at Gravatar, they should use an e-mail address which is not stored at Gravatar for commenting. We would also like to point out that it is also possible to use an anonymous e-mail address or no e-mail address at all if users do not wish their own e-mail address to be sent to Gravatar. Users can prevent the transmission of data completely by not using our comment system.
- Processed data types: Inventory data (e.g. names, addresses), contact data (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.B. Device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services).
- Purposes of processing: Contractual services and service, feedback (e.g.B. Collecting feedback via online form), security measures, administration and answering of inquiries, provision of our online services and user friendliness.
- Legal basis:Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), protection of vital interests (Art. 6 para. 1 sentence 1 lit. d. DSGVO).
Services and service providers in use:
- Akismet Anti-Spam Check: Akismet Anti-Spam Check; Service Provider: Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
- Profile images of Gravatar: Profile images; Service provider: Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://automattic.com; Privacy policy: https://automattic.com/privacy.
- WordPress.com: Hosting platform for blogs; Service provider: Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/.
Contacting
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.
Response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries.
- >Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos).
- Affected persons: Communication partners.
- >Purposes of processing: Contact inquiries and communication.
- Legal bases: Contract fulfilment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the framework of the provision of the hosting offer may include all information relating to the users of our online offer that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and -hosting: The webhosting services used by us also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and logfiles: We (or our webhosting provider) collect data on each access to the server (so-called server logfiles). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server logfiles can be used for security purposes, e.g. to avoid server overload (especially in case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.
- Processed data types: 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).
- Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Contacting
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed insofar as this is necessary to answer the contact enquiries and any requested measures.
Response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of the legitimate interests in answering the enquiries.
- >Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos).
- Affected persons: Communication partners.
- >Purposes of processing: Contact inquiries and communication.
- Legal bases: Contract fulfilment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).
Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the framework of the provision of the hosting offer may include all information relating to the users of our online offer that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and -hosting: The webhosting services used by us also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.
Collection of access data and logfiles: We (or our webhosting provider) collect data on each access to the server (so-called server logfiles). The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server logfiles can be used for security purposes, e.g. to avoid server overload (especially in case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.
- Processed data types: 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).
- >Affected persons: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Newsletter and Broadcasting
We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information on our services and us.
In order to subscribe to our newsletters, it is sufficient to enter your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.
Double-Opt-In-Procedure: The subscription to our newsletter is always done in a so-called Double-Opt-In-Procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise the changes of your data stored with the Versanddienstleister are logged.
Deletion and limitation of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address solely for this purpose in a black list.
The registration procedure is recorded on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Notes on legal bases: The newsletter is sent on the basis of the recipient’s consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests to demonstrate that it was conducted in accordance with the law.
Contents: Information to us, our achievements, actions and offers. Information about newly published articles and social media content.
Success measurement: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file, which is retrieved from our server or, if we use a dispatch service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are first collected.
This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to identify different contents.
The evaluation of the newsletter and the performance measurement are carried out, subject to the express consent of the user, on the basis of our legitimate interests for the purposes of using a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the user.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or contradicted.
Prerequisite for the use of free services: Consent to the sending of mailings may be made dependent on the use of free services (e.g. access to certain content or participation in certain campaigns) as a prerequisite for the use of free services. If the users would like to make use of the free service without registering for the newsletter, please contact us.
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. Visited websites, interest in content, access times).
- Affected persons: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g.B. by e-mail or post), contractual services and service.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
- Opposition (Opt-Out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.
Services and service providers in use:
- Mailchimp: E-mail marketing platform; service provider: “Mailchimp” – Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA; website: https://mailchimp.com; Privacy Policy: https://mailchimp.com/legal/privacy/; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active.
Online marketing
We process personal data for the purposes of online marketing, which includes in particular the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned contents is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use IP masking methods (i.e. pseudonymisation by shortening the IP address) to protect users. In general, the online marketing process does not store any user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or using similar procedures. These cookies can later generally be used on other websites that use the same online marketing process, read and analyzed for content presentation purposes, supplemented with additional data and stored on the server of the online marketing process provider.
Exceptionally, plain data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedures we use and the network connects the profiles of the users in the aforementioned data. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
We only get access to summarized information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. to a contract being concluded with us, for example. The conversion measurement is used solely to analyze the success of our marketing measures.
Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Affected persons: Users (e.g. website visitors, users of online services), interested parties.
- >Purposes of processing: Tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), coverage measurement (e.g.B. Access statistics, recognition of returning visitors).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. a DSGVO), Rights and obligations (Art. 6 Para. 1 DSGVO). 6 Paragraph 1 S. 1 lit. f. DSGVO).
- Opposition possibility (Opt-Out): We refer to the data protection information of the respective providers and the opposition possibilities indicated to the providers (so-called “Opt-Out”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. This may, however, cause functions to be disabled.
Services and service providers in use:
- Google Analytics: Online Marketing and Web Analytics; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-Out-Plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
Presences in social networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data may be processed outside the territory of the European Union. This may entail risks for users, e.g. because it may make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they are thus obligated to comply with the data protection standards of the EU.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The usage profiles can also be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged on to them).
For a detailed description of the respective forms of processing and the possibilities for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of rights of data subjects, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.
- Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g.e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- People affected: Users (e.g. Website visitors, users of online services).
- Purposes of processing: Contact enquiries and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, range measurement (e.g.B. Access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
Services and service providers in use:
- Instagram : Social Network; Service Provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: http://instagram.com/about/legal/privacy.
- Facebook: Social Network; Service Provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Privacy Shield (guarantee of data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy Notice for Facebook Pages: 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; Privacy Shield (guarantee of data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Twitter: Social Network; Service Provider: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy Statement: https://twitter.com/de/privacy, (preferences) https://twitter.com/personalization; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- YouTube: Social Network; 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 Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: https://adssettings.google.com/authenticated.
Plugins and embedded functions and content
We include functional and content elements in our online offer which are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These may, for example, be graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to 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 contain, among other things, technical information about the browser and operating system, websites to be referred to, visiting times and other information about the use of our online services as well as may be linked to such information from other sources.
Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis of the processing of data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), inventory data (e.g. names, addresses).
- >Affected persons: Users (e.g. website visitors, users of online services), communication partners.
- Purposes of processing: Provision of our online services and user-friendliness, contractual services and support, contact requests and communication, direct marketing (e.g.e.g. by e-mail or post), tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), feedback (e.g. collection of feedback via online forms), security measures, administration and response to enquiries.
- Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO), consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO).
Services and service providers in use:
- Facebook Social Plugins: Facebook Social Plugins – This can include content such as images, videos or text and buttons with which users can share content from this online service within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Privacy Shield (guarantee of data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
- Google Fonts: We integrate the fonts (\”Google Fonts\”) of the provider Google, whereby the data of the users are used solely for purposes of the representation of the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and under consideration of possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
- Instagram Plugins and Buttons: Instagram Plugins and Buttons – This may include content such as images, videos, or text and buttons with which users can share content from this online service within Instagram. Service provider: https://www.instagram.com, Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy Policy: http://instagram.com/about/legal/privacy.
- >LinkedIn Plugins and Buttons: LinkedIn Plugins and Buttons – This may include content such as images, videos, or text and buttons with which users can share content from this online service within LinkedIn. Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.instagram.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guarantee of data protection level when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Spotify Music Player Widget: Spotify Music Player Widget; Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden; Website: https://www.spotify.com/de; Privacy Policy: https://www.spotify.com/de/legal/privacy-policy/.
- YouTube: Videos; 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 Statement: https://policies.google.com/privacy; Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-Out: Opt-Out Plugin: http://tools.google.com/dlpage/gaoptout?hl=de; Advertising Display Settings: https://adssettings.google.com/authenticated.
Deletion of data
The data processed by us will be deleted in accordance with the statutory provisions as soon as their consent permitted for processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited 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 stored for commercial or tax 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 may also be provided within the framework of the individual data protection notices of this data protection declaration.
Change and update of the privacy policy
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Rights of the persons concerned
You are entitled to various rights under the DSGVO, in particular arising from Articles 15 to 18 and 21 of the DS-GVO:
- Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 Para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is connected with such direct advertising.
- Right of withdrawal in the case of consent: You have the right to revoke consent given at any time.
- >Right of access: You have the right to request confirmation as to whether the data concerned will be processed and to request information about this data as well as further information and a copy of the data in accordance with the statutory provisions.
- Right of correction: In accordance with the statutory provisions, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
- Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the data concerning you be deleted immediately, or alternatively, in accordance with the statutory provisions, to demand a limitation of processing of the data.
- Right to Data Transferability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to demand its transfer to another responsible party.
- Complaint to the supervisory authority: In accordance with the statutory provisions, you also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of presumed infringement, if you are of the opinion that the processing of your personal data violates the DSGVO.
Terms definitions
In this section you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them.
- Visit Promotion Evaluation: “Conversion Tracking” refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, we can track whether the ads we placed on other websites were successful).
- IP-Masking: “IP-Masking” is a method by which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing
- Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is defined as the process by which potential interests of users in ads and other content are determined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting certain websites and staying on them, purchasing behaviour 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 by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website. For example, we can track whether the ads we placed on other websites were successful.
- Personal data: “Personal data” is any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is any person who directly or indirectly, in particular by means of an assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g., a name, a telephone number, a telephone number, an e-mail address, a fax number, a telephone number, a telephone number, a fax number, etc.), or an e-mail address.B. Cookie) or to one or more specific characteristics which are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
- Profiling: “Profiling” means any automated processing of personal data consisting of the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (including, depending on the type of profiling, information relating to age, sex, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people).For example, interests in certain content or products, click behaviour on a website, or whereabouts.) Cookies and web beacons are often used for profiling purposes.
- Range measurement: Range measurement (also referred to as web analytics) is used to evaluate the visitor flows of an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can recognize, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For purposes of range analysis, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing: “Remarketing” or “Retargeting” is used when, for example, it is noted for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking: “Tracking” is when the behaviour of users can be traced across several online offers. As a rule, with regard to the online offers used, behavioural and interest information 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 display advertisements to users that are likely to correspond to their interests.
- Data controller: a “data controller” is a 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 carried out with or without the aid of automated means, or set of operations, on personal data. The term is broad and covers practically all handling of data, be it collection, analysis, storage, transmission or erasure.
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